Liquidators seeking approval of remuneration on a time-costing basis must provide material that enables the court to understand what work was performed and why it was necessary or appropriate — neither very general descriptions nor very detailed time-costing schedules alone will suffice. Gross inefficiency and unjustifiable delay in finalising a liquidation will result in substantial reductions to approved remuneration, as the court assesses the value of services rendered rather than indemnifying against cost. Where mixed funds in a fraudulent scheme are insufficient to meet all claims and tracing is impossible, rateable distribution is appropriate, and the court may direct distribution to only one class of investors where equity between classes so requires.
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