The balance of convenience is not a mandatory precondition for the making of a freezing order; it is merely one among multiple discretionary considerations. The 'good arguable case' threshold for a freezing order pending appeal equates to a real prospect of success and is not more stringent than the general leave to appeal requirement. On security for costs, where a respondent has substantial offsetting costs liabilities to the applicant and the applicant is impecunious, the respondent bears the onus of establishing that the costs offset is inadequate, and ordering security that would stifle an arguable appeal based on established misconduct may be unjust.
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