The test for risk of dissipation of assets in support of a freezing order under O 52A r 5(4) of the Rules of the Supreme Court 1971 (WA) does not require proof of a positive intention to place assets beyond the reach of the plaintiff. It is sufficient to show a danger that a prospective judgment will be wholly or partly unsatisfied because assets are disposed of, dealt with or diminished in value. The liquidation of a principal asset and conversion to cash, combined with evidence of dishonest conduct, may be sufficient to establish the requisite risk.
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