A 'walk-away' Calderbank offer (dismissal with no order as to costs) can constitute a genuine offer of compromise, and its unreasonable rejection may ground an indemnity costs order. Filing a security for costs application against natural persons without prior correspondence and without any proper basis to overcome the principle against ordering security on account of impecuniosity may result in indemnity costs. The court articulated nine points of practical guidance requiring legal practitioners to attempt to resolve interlocutory matters before filing motions, treating the filing of a motion as a last resort.
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