Security for costs may be ordered on appeal where the applicant's sole ground is denial of a fair hearing but the trial transcript demonstrates the judge provided extensive assistance to the unrepresented litigant, and the applicant does not challenge any factual findings. The Stead futility principle applies where unchallenged factual findings mean a retrial would inevitably produce the same result. The amount of security ordered should reflect the narrow scope of the issues on appeal.
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