Litigation Letter
Order against non-party – 2
BE Studios Ltd v Smith & Williamson Ltd [2005] All ER (D) 33 (Dec); ChD TLR 16 December
Where a director has funded and controlled litigation brought by his company, it is not necessary to demonstrate that he has
been guilty of some impropriety or bad faith in procuring the company to prosecute the claim in order to make a non-party
costs order against him.