The Court ordered security for costs of $253,000 against an overseas plaintiff who had no Australian assets, where the evidence demonstrated a real risk that registration and enforcement of any costs judgment in the United Kingdom would be rendered long, complex and costly by the plaintiff's established pattern of taking meritless points to resist enforcement. The Court accepted that while reciprocal enforcement arrangements between Australia and the UK ordinarily facilitate registration of judgments, the plaintiff's prior conduct in UK proceedings — including applications found to be 'totally without merit' and conduct characterised as 'obviously fraudulently' designed to place assets beyond creditors' reach — justified ordering security for the full estimated costs of defending the proceedings rather than merely the estimated costs of overseas enforcement.
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