Impecuniosity of a natural person appellant is ordinarily insufficient to constitute 'special circumstances' under UCPR r 51.50, consistent with the policy in r 42.21(1B). The jurisdiction under r 51.50 is not intended to be broader in this respect than the general security for costs jurisdiction. Where an appeal from a circumstantial evidence case does not involve a simple word-against-word credibility contest, the high barrier to appellate intervention in Fox v Percy may not apply.
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