The court proposed the form of the order following the appellant's successful appeal in which the court set aside various orders made against him in relation to a fraud action. Where one party had undertaken not to begin proceedings against another on the same subject matter in another jurisdiction without leave of the court and was the quid pro quo for the grant of a world wide freezing order, the undertaking took effect as if it was an injunction against the party giving the undertaking.

[2001] EWCA Civ 1370

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