A natural person who adopts a vexatious mode of conducting litigation — including bringing misconceived interlocutory applications, persisting in arguments determined against them, and making unfounded allegations — falls within an exception to the general rule that impecunious natural persons will not be ordered to provide security for costs. The unmeritorious conduct of interlocutory applications resulting in unpaid costs orders may evidence a vexatious mode of conducting litigation, though the bare fact of unpaid interlocutory costs orders is not sufficient. Where security is ordered against an impecunious litigant, the quantum should be set at a level that does not unnecessarily stultify the proceeding.
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