Unexplained post-judgment dissipation of assets, when combined with impecuniosity, absence of evidence of stultification, and procedural non-compliance, constitutes special circumstances justifying security for costs of an appeal under UCPR r 51.50. The dissipation of assets principle from Green v CGU Insurance Ltd applies in the UCPR r 51.50 context. Interlocutory findings on a freezing order application do not constitute final findings of fact, but undisputed documentary evidence from such proceedings may be relied upon in a subsequent security for costs application.
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