A substantial gift to a spouse made well before a dispute arose and when the donor still held significant other funds is not properly characterised as dissipation of assets constituting 'special circumstances' for security for costs under UCPR r 51.50. Stultification does not necessarily follow from impecuniosity where a spouse with substantial equity has not given evidence of unwillingness to provide security. An appellant who has sworn unchallenged affidavits as to financial position is distinguishable from cases where financial disclosure was inadequate or unsworn.
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