Appellants suing in a representative capacity as trustee of a discretionary trust may constitute 'special circumstances' under UCPR r 51.50 when combined with doubt about ability to satisfy a costs order and evidence of fraudulent conduct.
The full text is available to signed-in members, including the 3 later cases that cite this judgment.
1 of the 3 citing cases carry a classified treatment. How each court treated it is available to signed-in members.