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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
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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