UCPR r 772 confers an unfettered discretion to order security for costs of an appeal. Poor prospects of success on appeal from a discretionary order, combined with the appellant's recent bankruptcy originating from failure to pay costs, present a reasonably compelling case for security. The risk of stifling an appeal is to be weighed conservatively where the appellant has already had the benefit of judicial consideration of the underlying issues and has not shown that the respondents' conduct caused his impecuniosity.
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