Macedonian Orthodox Community Church St Petka Incorporated v His Eminence Metropolitan Petar Diocesan Bishop of the Macedonian Orthodox Diocese of Australia and New Zealand

Security for costs may be refused where litigation concerns a charitable trust and involves the religious and community life of ordinary people in a community dispute, even where the appellant is likely unable to pay costs, because the public interest and the interest in just resolution of the dispute outweigh the respondent's interest in security. A differential approach to individuals and corporations in the one appeal is ordinarily inappropriate.