The power to order a gross sum for costs under Pt 52A r 6(2)(c) may be exercised where assessment would be protracted and expensive, particularly where the costs debtor cannot meet the likely liability. The approach to estimation must be logical, fair and reasonable but is necessarily broad-brush. A gross sum order may be directed to one of several jointly and severally liable parties without joining the others. A certified copy of the minute of a gross sum order is fairly arguable to constitute a 'costs certificate' for the purposes of a bank guarantee.
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