The Court of Appeal has inherent power to order security for costs in judicial review proceedings, not just appeals, and UCPR r 51.50 does not apply to proceedings in the Court's supervisory jurisdiction. Security for costs may be ordered against an impecunious natural person even where the order would stultify the proceedings, where the proceedings constitute an abuse of process, the litigant has already had the merits determined, and the challenge has no arguable basis. The considerations justifying security on appeal (that rights have already been adjudicated) are diminished still further where the Legislature has conferred largely exclusive jurisdiction on a specialist tribunal with only limited rights of appeal on questions of law.
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