Under the Supreme Court (Court of Appeal) Rules 2005 (WA), the discretion to order security for costs of an appeal is unfettered. Residence outside Australia, absence of assets within the jurisdiction, non-payment of costs below, and statements of intention not to pay costs are relevant factors supporting an order for security.
The full text is available to signed-in members, including the 5 later cases that cite this judgment.
2 of the 5 citing cases carry a classified treatment. How each court treated it is available to signed-in members.