Changed circumstances including voluntary administration, entry into a DOCA with litigation funding arrangements, additional costs incurred in failed interlocutory applications, and failure to pay even modest fixed costs orders are capable of justifying a court revisiting the quantum of security for costs previously ordered. The prospect that a further security order would stultify the litigation, while a significant factor, is only one of the factors to be weighed and does not preclude the making of a further order.
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