A court may exercise its inherent power to restrain a litigant from making interlocutory applications without leave where there is a history of unmeritorious satellite litigation, repeated refusal to accept rulings, and persistent improper behaviour. The restraining order may extend to requiring all future applications and hearings to be conducted by written submissions only, and may specifically restrain repeated disqualification applications unless based on cogent fresh evidence. The appropriate procedure is to issue a show cause order before making final restraining orders.
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