Stultification of litigation is not a prerequisite for refusal of an order for security for costs, including in public interest litigation. Proportionality between the potential costs liability and the overall cost of the development project is a relevant consideration in the security for costs discretion, even where there is no finding that an order would prevent the litigation from proceeding. A judicial officer exercising the security for costs discretion is not required to address considerations that do not apply in the particular case.
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