[2012] EWCA Civ 1411

There was no authority for the proposition that a full hearing on the merits was required in circumstances where a litigant had forfeited his right to a full trial by his own conduct of the litigation. The judge had been entitled to make orders whereby the appellant would be debarred from defending the claims against him unless within a stated period he both surrendered to custody and made proper disclosure of all his assets and his dealings with them.

CA (Civ Div) (Sir Maurice Kay (VP CA Civ), Rix LJ, Toulson LJ)


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