Practitioners seeking non-party costs orders against sole directors/shareholders of unsuccessful corporate plaintiffs must demonstrate something beyond the ordinary incidents of sole directorship — such as objectively unreasonable or improper conduct of the litigation — and cannot rely merely on the director being the guiding mind, funder, and beneficiary of the litigation, even where personal animosity is present.
The full text is available to signed-in members, including the 25 later cases that cite this judgment.
4 of the 25 citing cases carry a classified treatment. How each court treated it is available to signed-in members.