Liquidators who unsuccessfully appeal from a refusal of directions will ordinarily be ordered to pay costs personally and bear the onus of establishing entitlement to indemnity from company assets. The costs must be shown to have been honestly and reasonably incurred; mere bona fides or absence of impropriety is insufficient. Where all creditors oppose the course adopted and the compromise would confer a collateral benefit on the liquidators, the onus is unlikely to be discharged.
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