The court confirmed that additional security for costs may be ordered where material changes of circumstances have occurred since the original order, including the incarceration of a plaintiff company's sole director, the inability to fund litigation, and the anticipated increase in hearing length due to self-representation. The determination of quantum is a broadbrush exercise not intended to provide a complete indemnity. The court accepted that 80% of solicitor/client costs may be too high a discount rate for party/party recovery when s 172(1) of the Legal Profession Uniform Law (NSW) 2014 is taken into account.
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