A personal undertaking by a sole director to guarantee costs is insufficient as an alternative to a security for costs order where the director's financial disclosure is unreliable, lacking in detail, and the stated asset position is thrown into doubt by concessions about contingent assets. Causation of impecuniosity by the respondent is of reduced significance on appeal because the respondent has the advantage of a judgment in its favour. In cases other than Family Provision Act matters, it is rare for an unsuccessful appellant to avoid a costs order, so the mere possibility of no costs order does not preclude a security order.
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