A corporate appellant's impecuniosity may be established through circumstantial evidence including payments from separate entities, absence of voluntary payments, failure to commence proceedings requiring security, establishment of similarly-named companies, and a Jones v Dunkel inference from failure to adduce evidence of financial position. The relevance of the arguability of an appeal to the quantum of security for costs was questioned but not definitively resolved.
The full text is available to signed-in members, including the 3 later cases that cite this judgment.
2 of the 3 citing cases carry a classified treatment. How each court treated it is available to signed-in members.