An appellant's non-compliance with prior costs orders, steps to put assets beyond creditors' reach, and intention to leave the jurisdiction are together sufficient to justify an order for security for costs of an appeal. A stay application that seeks to stay the whole of primary proceedings will be refused where the scope of the stay goes beyond what could be justified even if the appeal succeeded. Under the Supreme Court (Court of Appeal) Rules 2005 (WA), special circumstances need not be shown for security for costs in the Court of Appeal, unlike in the General Division.
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