The test for 'special circumstances' under r 1905 of the Court Procedure Rules 2006 (ACT) is that stated in [name withheld] v Moneycorp Securities Pty Ltd, requiring new material with evidence of additional facts arising or discovered since the original order. A deed of indemnity from an overseas insurer may be adequate security for costs where usual forms are beyond the plaintiff's means, but additional payment into court for overseas enforcement costs will be required.
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