Costs – Security for costs. The Chancery Division held that the claimant (C) would be ordered to pay an additional £830,000 as security for costs in a case where C had already paid £500,000 and the defendant (D) had sought an extra £1m. In the circumstances, the total costs estimated by D were seriously disproportionate. However, in view of the sparse evidence on C's expenditure, it was not appropriate to reduce the amount of security ordered by reason of the lack of an undertaking from D to compensate C for loss caused by the putting up of security.