Impecuniosity of an appellant can of itself amount to 'special circumstances' under Part 51 rule 16(1), though orders would not normally be made on that basis alone. Security for costs of an appeal is not limited to cases where a prima facie abuse of process is established, disapproving Abdurahman v Field to that extent. Additional factors such as the magnitude of unrecoverable costs already incurred, the difficulty of the appeal, and the lack of general importance are relevant to the exercise of the discretion.
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