A $2 paid-up capital company with no real property and no affidavit evidence of assets will be ordered to provide security for costs where the appeal has no realistic prospects of success. A corporation must be represented by a lawyer in Court of Appeal proceedings pursuant to r 1.17 of the Supreme Court Rules, and an undischarged bankrupt without trustee consent cannot represent the company. The onus lies on the party opposing security to adduce evidence of oppression or causation of impecuniosity.
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