A court may exercise its inherent power to restrain a litigant from bringing interlocutory applications without leave and to require all further proceedings to be conducted by written submissions only, where the litigant has persistently abused the court's process through vexatious applications, unfounded bias allegations, and misconduct during oral hearings. Such orders should be made only as a very last resort but are justified where the litigant's conduct has been egregious and persistent.
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