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United Kingdom angel bell exceptionpost judgment enforcement

Emmott v Michael Wilson & Partners

Michael Wilson & 'Partners' Ltd v Emmott [2019] EWCA Civ 219
JurisdictionUnited Kingdom
CourtCourt of Appeal (Civil Division)
Year2019
StatusBinding authority

Key Principle

Whether to remove the 'Angel Bell' exception (which permits a defendant to make payments, including reasonable legal expenses, in the ordinary course of business) from a post-judgment freezing injunction is a fact-specific discretionary decision; its removal is not a starting point or presumption, and the more draconian the relief, the greater the justification required.

Area of Law

General

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