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Mostyn J summarised in the judgment the principles and safeguards relevant to freezing injunctions.

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Here an order was made which granted the husband the right to apply to set aside or vary the order but only on giving 48 hours notice.

Nothing in the order or the note of the hearing explains why the husband's rights under rules 18.10 and 18.11 were cut down.5.

Application by a wife in financial remedy proceedings for the continuation of an ex parte freezing order in respect of the husband's assets.

Guidance provided (with the authority of the President) on the use, necessary safeguards and form of freezing and search orders in such cases.

It is remarkable for this freezing order to have omitted every single standard safeguard and to have frozen, in addition to the Marbella property, other assets up to £20m held in the husband's sole name when the wife had positively deposed to a belief that he did not actually have any. However, entirely without prejudice (a) to that contention and (b) his claim that he in fact has no legal or beneficial interest in the Marbella property, and in a spirit of pragmatism, he offers an undertaking that he will take no steps to dispose of charge or otherwise deal with it, nor will he encourage the company that owns it to do so. In their careful written submissions for the husband at para 44 Miss Bangay QC and Mr Hagen argue that it is likely to be a solecism to refer to the general power of the High Court to grant a freezing order as arising only under the "inherent jurisdiction of the court".