An application to set aside a perfected judgment on the ground of fraud must be brought in separate proceedings, not by motion, except in the simplest of cases. UCPR Pt 36 r 36.15(1) has only limited application to judgments made after a hearing on the merits. Repeated applications for leave to appeal from the same interlocutory judgment, without any change of circumstances or fresh argument, constitute an abuse of process and may be summarily dismissed in chambers under a Teoh order.
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