Palyanitsa Ltd v Bridgetower Capital Ltd [2025] SGHCR 21

Case Details

• Citation: [2025] SGHCR 21
• Court: General Division of the High Court
• Decision Date: 4 July 2025
• Coram: Assistant Registrar Leo Zhi Wei
• Case Number: Originating Claim No 139 of 2024; Summonses Nos 506 and 1132 of 2025
• Hearing Date(s): 26 May 2025
• Claimants / Plaintiffs: Palyanitsa Ltd
• Respondent / Defendant: Bridgetower Capital Ltd
• Counsel for Claimants: Yam Wern-Jhien, Ian Mah, Ayana Ki (Setia Law LLC)
• Counsel for Respondent: Tan Mei Yen, Lee Chia Ming, Clare, Tham Kai Lun, Josiah (Ascendant Legal LLC)
• Practice Areas: Civil Procedure – Summary Judgment; Civil Procedure – Pleadings; Contract – Formation

Summary

The decision in Palyanitsa Ltd v Bridgetower Capital Ltd [2025] SGHCR 21 represents a significant interlocutory milestone in the evolving landscape of cryptocurrency litigation in Singapore. The dispute centers on a "Staking Agreement" involving 1,000,000 NEAR Tokens, where the primary conflict arises from the characterization of the transfer of these digital assets—specifically, whether the transfer constituted a bailment/trust arrangement for staking services or an outright transfer of ownership. The Claimant, Palyanitsa Ltd, sought summary judgment for the return of the tokens or their value, alleging breach of contract and breach of trust. Conversely, the Defendant, Bridgetower Capital Ltd, sought to amend its pleadings to introduce complex defenses involving agency and disputed ownership, asserting that the Claimant acted merely as an agent for the NEAR Foundation.

The court was tasked with balancing the efficiency of the summary judgment mechanism against the necessity of a full trial when "triable issues" are raised. Assistant Registrar Leo Zhi Wei’s judgment provides a meticulous examination of the threshold for summary judgment under the Rules of Court 2021 (ROC 2021). The decision clarifies that while a claimant may establish a prima facie case, the presence of "triable issues" or "some other reason" for a trial—such as the need for cross-examination to resolve conflicting factual narratives regarding the commercial context of a digital asset transaction—will preclude summary disposal. This is particularly relevant in the cryptocurrency sector, where the nomenclature of "staking" and "transfer" may not always align with traditional legal categories of property and possession.

Furthermore, the judgment delves into the principles governing the amendment of pleadings. Applying the framework established in [2023] SGHC 216, the court emphasized that the primary consideration is whether the amendments are necessary to determine the real issues in controversy without causing irreparable prejudice to the opposing party. The court's willingness to allow amendments that refined the Defendant's agency and ownership defenses, while rejecting certain counterclaims as factually unsustainable, demonstrates a nuanced approach to procedural fairness. The decision serves as a reminder that in the "new" ROC 2021 regime, the court retains broad discretion to ensure that the merits of a complex commercial dispute are fully ventilated at trial rather than prematurely stifled.

Ultimately, the court dismissed the Claimant's application for summary judgment and granted the Defendant unconditional leave to defend. This outcome underscores the judicial caution applied to high-value cryptocurrency disputes where the underlying contractual intent and the status of the parties (as principals or agents) are contested. By refusing to summarily resolve the ownership of the 1,000,000 NEAR Tokens, the court affirmed that the complexities of digital asset "staking" agreements often require the robust evidentiary scrutiny of a full trial, particularly when the parol evidence rule and the commercial matrix of the transaction are in play.

Timeline of Events

1. 5 September 2022: Initial interactions or preliminary steps leading toward the contractual relationship between the parties.
2. 10 September 2022: The Claimant (Palyanitsa Ltd) and the Defendant (Bridgetower Capital Ltd) enter into the Staking Agreement. Pursuant to this agreement, 1,000,000 NEAR Tokens are transferred to the Defendant.
3. 1 December 2022: A critical date in the factual matrix where the Defendant alleges the Staking Agreement was effectively terminated or superseded by direct dealings with the NEAR Foundation.
4. 20 September 2023: A date of relevance regarding the subsequent communications or disputes between the parties leading to litigation.
5. 19 October 2023: Further factual developments or correspondence cited in the procedural history.
6. 5 March 2024: The Suit (Originating Claim No 139 of 2024) is officially commenced by the Claimant.
7. 17 April 2024: Procedural milestone following the commencement of the suit.
8. 12 July 2024: Filing or service of key pleadings in the ongoing litigation.
9. 8 October 2024: Procedural development in the lead-up to the interlocutory applications.
10. 17 December 2024: Further procedural step in the management of the case.
11. 20 January 2025: Filing of Summons No 506 of 2025 (the Claimant's application for summary judgment).
12. 6 February 2025: Related procedural date concerning the summonses.
13. 10 February 2025: Filing of Summons No 1132 of 2025 (the Defendant's application to amend the Defence and Counterclaim).
14. 24 February 2025: Deadline or hearing date related to the exchange of affidavits for the summonses.
15. 3 March 2025: Further procedural date in the lead-up to the substantive hearing of the summonses.
16. 10 March 2025: Procedural milestone for the filing of further evidence or submissions.
17. 28 March 2025: Continued case management and preparation for the hearing.
18. 9 April 2025: Finalization of the hearing schedule for the interlocutory applications.
19. 9 May 2025: Filing of final submissions or bundles for the hearing.
20. 26 May 2025: Substantive hearing of SUM 506 and SUM 1132 before Assistant Registrar Leo Zhi Wei.
21. 4 July 2025: Delivery of the judgment in [2025] SGHCR 21.

What Were the Facts of This Case?

The dispute in Palyanitsa Ltd v Bridgetower Capital Ltd arises from a commercial arrangement within the cryptocurrency industry, specifically involving the NEAR Protocol blockchain. The Claimant, Palyanitsa Ltd, is a company involved in blockchain infrastructure. The Defendant, Bridgetower Capital Ltd, is a Singapore-incorporated entity providing blockchain infrastructure and staking services. On or about 10 September 2022, the parties entered into a "Staking Agreement." Under the terms of this agreement, the Claimant transferred 1,000,000 native digital utility tokens of the NEAR Protocol ("NEAR Tokens") to the Defendant. At the time of the dispute, the value of these tokens was substantial, with references in the proceedings to sums in the region of US$3.65 million.

The core of the Staking Agreement involved the Defendant using the 1,000,000 NEAR Tokens to run staking nodes. Staking, in the context of blockchain, typically involves locking up digital assets to support the operation and security of a blockchain network in exchange for rewards. The Claimant alleged that the Defendant was obligated to provide staking services, share the rewards generated, and eventually return the principal amount of tokens. However, the Claimant contended that the Defendant breached the agreement by failing to provide updates, failing to share rewards, and ultimately failing to return the 1,000,000 NEAR Tokens upon demand. The Claimant further alleged that the Defendant had "unstaked" the tokens and transferred them to its own private wallet, thereby misappropriating the assets. This led to claims for breach of contract, breach of fiduciary duty, and breach of trust (specifically a Quistclose trust).

The Defendant's narrative was fundamentally different. It argued that the Staking Agreement was not a simple service contract but part of a broader commercial arrangement involving the NEAR Foundation, a Swiss non-profit entity responsible for the NEAR Protocol. The Defendant raised an "Agency Defence," asserting that the Claimant had entered into the Staking Agreement merely as an agent for the NEAR Foundation. According to the Defendant, the 1,000,000 NEAR Tokens actually belonged to the NEAR Foundation, and the Claimant had no standing to sue for their return. The Defendant pointed to the fact that the tokens were transferred from a wallet associated with the NEAR Foundation and that subsequent negotiations regarding the tokens involved Foundation representatives.

Furthermore, the Defendant raised an "Ownership Defence." It contended that the parties intended for the full legal and beneficial ownership of the 1,000,000 NEAR Tokens to be transferred to the Defendant as part of a "grant" or an incentive for the Defendant to build infrastructure on the NEAR Protocol. The Defendant argued that the term "transfer" in the Staking Agreement, when read in the commercial context, implied a permanent change in ownership rather than a temporary bailment. The Defendant alleged that on 1 December 2022, the Staking Agreement was effectively terminated when the NEAR Foundation indicated that the Claimant was no longer authorized to act on its behalf. Following this, the Defendant claimed it entered into a new arrangement directly with the NEAR Foundation regarding the tokens.

The procedural history of the case is marked by the Claimant's aggressive pursuit of summary judgment. Following the commencement of the suit on 5 March 2024, the Claimant filed SUM 506 on 20 January 2025, arguing that the Defendant had no real prospect of successfully defending the claim. The Defendant responded by filing SUM 1132 on 10 February 2025, seeking to amend its Defence and Counterclaim to more clearly articulate the agency and ownership arguments and to introduce a counterclaim for loss of opportunity and reputational damage. The Defendant's proposed amendments were met with stiff resistance from the Claimant, who argued that the amendments were "hopeless," "factually unsustainable," and an attempt to delay the inevitable summary judgment.

The evidence before the court included the Staking Agreement itself, various blockchain transaction records, and extensive email and Telegram correspondence between representatives of the Claimant, the Defendant, and the NEAR Foundation. The Claimant relied heavily on the literal text of the agreement, while the Defendant emphasized the "commercial matrix" and the conduct of the parties. The court was thus faced with a classic conflict between a "plain meaning" interpretation of a contract and a "contextual" approach, set against the backdrop of a rapidly evolving and technically complex industry.

What Were the Key Legal Issues?

The interlocutory applications raised several critical legal issues that required the court to navigate both procedural rules and substantive contract law principles:

• The Threshold for Amending Pleadings under ROC 2021: The court had to determine whether the Defendant's proposed amendments to its Defence and Counterclaim should be allowed. This involved applying the "real issues in controversy" test and considering whether the amendments were "plainly and obviously" unsustainable or brought in bad faith.
• The Agency Issue (Standing): A central issue was whether the Claimant acted as an agent for the NEAR Foundation. If the Claimant was indeed an agent for a disclosed or undisclosed principal who owned the tokens, its standing to sue in its own name for the return of the assets would be called into question.
• The Ownership Issue (Contractual Interpretation): The court had to consider whether the transfer of 1,000,000 NEAR Tokens under the Staking Agreement was intended to pass full beneficial ownership to the Defendant or whether it created a trust or bailment relationship. This required an analysis of the term "transfer" and the applicability of the parol evidence rule under sections 93 and 94 of the Evidence Act 1893.
• The Summary Judgment Standard: Under Order 9 Rule 16 of the ROC 2021, the court had to decide if the Claimant had established a prima facie case and, if so, whether the Defendant had raised a "triable issue" or "some other reason" why there ought to be a trial.
• The Existence of a Quistclose Trust: The Claimant asserted that the tokens were transferred for a specific purpose (staking), creating a trust. The court had to evaluate whether this claim was so clear-cut as to warrant summary judgment or whether the Defendant's competing narrative of an outright grant created a triable dispute.
• Factually Unsustainable Counterclaims: The court had to assess whether the Defendant's proposed counterclaims for loss of opportunity and reputational damage met the threshold of being "arguable" or whether they should be struck out/disallowed as fanciful.

How Did the Court Analyse the Issues?

The court’s analysis began with the Defendant’s application to amend its pleadings (SUM 1132), as the state of the pleadings would necessarily define the scope of the summary judgment application (SUM 506). Assistant Registrar Leo Zhi Wei applied the principles from [2023] SGHC 216, noting that under Order 9 Rule 14(1) of the ROC 2021, the court retains broad discretion to allow amendments at any stage. The primary focus is whether the amendment enables the "real issues in controversy" to be determined. The court also referenced [2023] SGHC 223, which highlights the inverse relationship between the lateness of the amendment and the court's willingness to grant it. In this case, as the suit was still in its early stages, the prejudice to the Claimant was deemed manageable through costs.

Regarding the "Agency Defence," the court found that the Defendant had raised an arguable case. The Defendant pointed to evidence that the NEAR Tokens originated from a Foundation-linked wallet and that the Claimant’s representatives often spoke on behalf of the Foundation. The court noted that the determination of whether a party acts as an agent is a fact-intensive inquiry. Quoting Bhoomatidevi d/o Kishinchand Chugani v Nantakumar s/o V Ramachandra [2023] 4 SLR 1644, the court observed that the "proper parties to the contract" must be determined by looking at the objective evidence. Because the Defendant’s narrative was supported by some documentary evidence (emails and Telegram messages), the court held that this issue could not be dismissed as "fanciful" at the amendment stage.

The "Ownership Defence" presented a more complex challenge involving the parol evidence rule. The Claimant argued that the Staking Agreement was an "entire agreement" and that extrinsic evidence could not be used to vary the term "transfer" to mean "grant of ownership." However, the court, citing Sembcorp Marine Ltd v PPL Holdings Pte Ltd [2013] 4 SLR 193, noted that extrinsic evidence is admissible to identify the commercial context and the "relevant surrounding circumstances." The court found that the Defendant’s argument—that the 1,000,000 NEAR Tokens were an incentive for infrastructure development—was a "triable issue." The court observed:

"The reason the court has regard to the relevant context is to minimize the risk that the court’s interpretation of the text departs from the meaning that the parties actually intended to convey." (at [52], referencing Singapore Pte Ltd v B-Gold Interior Design & Construction Pte Ltd [2008] 3 SLR(R) 1029).

Turning to the summary judgment application (SUM 506), the court applied the two-stage test from Akfel Commodities Turkey Holding Anonim Sirketi v Townsend, Adam [2019] 2 SLR 412. First, the Claimant must show a prima facie case. The court agreed that the Claimant had done so by producing the Staking Agreement and proving the transfer of tokens. However, the burden then shifted to the Defendant to show a "triable issue." The court found that the Agency and Ownership Defences were not "plainly sustainable" but were "arguable." The court emphasized that summary judgment is not intended for cases where there are "disputed issues of fact" that require cross-examination. The conflicting accounts of the 1 December 2022 meeting and the true nature of the "staking" arrangement were precisely the types of disputes that required a full trial.

The court also addressed the Claimant's trust claim. The Claimant argued that the tokens were held on a Quistclose trust, citing AG v Aljunied-Hougang-Punggol East Town Council [2014] 4 SLR 474. The court held that for a Quistclose trust to exist, there must be a clear intention that the assets be used only for a specific purpose and not fall into the recipient's general assets. Given the Defendant's argument that the tokens were a "grant" of ownership, the court found that the intention behind the transfer was a "live issue." It was not "clear beyond doubt" that a trust had been created. Consequently, summary judgment on the trust claim was also denied.

Finally, the court scrutinized the Defendant's proposed counterclaims. While the amendments to the Defence were largely allowed, the court was less permissive regarding the counterclaims for loss of opportunity and reputational damage. The court found these to be "factually unsustainable" and lacking in specific particulars. Applying the principle from Iskandar bin Rahmat and others v Attorney-General and another [2022] 2 SLR 1018, the court disallowed these portions of the amendment, as they had no reasonable prospect of success. However, the core of the Defence was allowed to proceed to trial.

What Was the Outcome?

The court’s decision resulted in a significant procedural victory for the Defendant, effectively halting the Claimant's attempt to resolve the matter without a full trial. The operative orders were as follows:

1. SUM 1132 (Amendment Application): The court allowed the Defendant's application in part. The Defendant was permitted to amend its Defence to include the refined Agency Defence and Ownership Defence. However, the proposed counterclaims for loss of opportunity and reputational damage were disallowed as they were found to be factually unsustainable and lacked a reasonable prospect of success.
2. SUM 506 (Summary Judgment Application): The Claimant's application for summary judgment was dismissed in its entirety. The court found that while the Claimant had established a prima facie case, the Defendant had successfully raised triable issues regarding the ownership of the tokens and the capacity in which the Claimant entered into the agreement.
3. Leave to Defend: The Defendant was granted unconditional leave to defend the suit. This means the Defendant does not need to provide security for the claim amount as a condition for proceeding to trial.
4. Costs: The court reserved the issue of costs. Parties were directed to provide written submissions on costs, limited to five pages each, by 18 July 2025, unless they could reach an agreement independently.

The court's final disposition was summarized in the following operative paragraph:

"For the foregoing reasons, I allow SUM 1132 in part, dismiss SUM 506 and grant the Defendant unconditional leave to defend its claims in the Suit." (at [137])

The dismissal of the summary judgment application means that the dispute over the 1,000,000 NEAR Tokens (valued at approximately US$3.65 million) will proceed to a full trial. This will involve the discovery of documents and the cross-examination of witnesses to determine the true nature of the commercial relationship between Palyanitsa, Bridgetower, and the NEAR Foundation. The court's refusal to grant even conditional leave to defend (which might have required the Defendant to pay the disputed sum into court) indicates that the Defendant's arguments, while contested, were sufficiently robust to meet the "triable issue" threshold without being viewed as "shadowy" or "dubious."

Why Does This Case Matter?

Palyanitsa Ltd v Bridgetower Capital Ltd is a landmark decision for practitioners involved in Singapore's burgeoning cryptocurrency and digital asset legal sector. Its significance lies in several key areas of law and practice:

1. Summary Judgment in the Crypto Context: The case reinforces the high threshold for summary judgment in disputes involving novel asset classes. Cryptocurrency transactions often involve "staking," "wrapping," or "liquidity provision"—terms that do not always have a fixed meaning in traditional property law. By dismissing the summary judgment application, the court acknowledged that the "commercial matrix" of these transactions is often too complex to be resolved on affidavits alone. This provides a strategic roadmap for defendants in crypto-litigation: by grounding defenses in the specific commercial context and the conduct of the parties, they can successfully argue that a full trial is necessary.

2. Agency and Standing in Decentralized Ecosystems: The "Agency Defence" raised by the Defendant is particularly relevant to the blockchain world, where "Foundations" often operate through various intermediaries, service providers, and community members. The court's willingness to entertain the possibility that a signatory to a contract was merely an agent for a blockchain foundation—despite the absence of express agency language in the document—highlights the importance of looking at the "proper parties" to a contract. This has broad implications for how entities in the NEAR, Ethereum, or other ecosystems structure their service agreements.

3. Contractual Interpretation and the Parol Evidence Rule: The judgment provides a modern application of the Evidence Act 1893 to digital asset contracts. It clarifies that even with an "entire agreement" clause, extrinsic evidence of the commercial context is admissible to assist the court in interpreting terms like "transfer." This prevents a purely literalist interpretation of "transfer" (which might imply a bailment) from overriding a potential commercial reality where the "transfer" was intended as an outright grant or incentive. Practitioners must be aware that the "plain meaning" of a crypto-contract may be challenged by the "surrounding circumstances."

4. Procedural Rigor under ROC 2021: The decision demonstrates the court's commitment to the "Ideals" of the ROC 2021, particularly the expeditious resolution of cases and the use of judicial discretion to ensure substantive justice. The court's detailed analysis of the amendment application shows that while the "new" rules encourage efficiency, they do not sacrifice the right of a party to bring a legitimate (even if complex) defense. The rejection of the "factually unsustainable" counterclaims also shows that the court will not allow parties to clutter the record with hopeless arguments.

5. Trust Law and Digital Assets: The discussion of Quistclose trusts in the context of NEAR Tokens adds to the growing body of Singapore case law (such as Quoine Pte Ltd v B2C2 Ltd) regarding the application of equity to digital assets. The court's finding that the intention to create a trust was a "triable issue" suggests that claimants seeking to assert trust-based remedies over crypto-assets will need very clear evidence of a "segregated purpose" for the transfer to succeed at a summary stage.

In the broader Singapore legal landscape, this case serves as a warning to those who draft "standard" staking agreements. If the parties intend for a transfer of tokens to be a bailment, a loan, or a grant, the language must be unmistakably clear. Relying on the general term "transfer" in a technically complex industry is an invitation to protracted litigation. For litigators, the case confirms that the "triable issue" remains a powerful shield against summary judgment, especially when the dispute involves the "commercial heart" of a transaction that the court has not yet fully categorized.

Practice Pointers

• Drafting Precision in Staking Agreements: Avoid using ambiguous terms like "transfer" in isolation. Explicitly state whether the transfer of digital tokens is intended to pass legal and beneficial title (a grant), create a bailment (possession without title), or establish a trust relationship. If the tokens are to be returned, specify the conditions and the exact "form" of the return (e.g., the same tokens or equivalent value).
• Clarifying Agency Status: When dealing with blockchain foundations or decentralized autonomous organizations (DAOs), clearly identify the principal in the contract. If a party is acting as an agent, use express agency language. Conversely, if a party is intended to be the sole principal with standing to sue, include a "no agency" or "independent contractor" clause to mitigate the risk of an "Agency Defence" being raised later.
• Documenting Commercial Context: Since the court will look at the "commercial matrix" to interpret the contract, ensure that pre-contractual negotiations (emails, Telegram, Discord) are consistent with the final written agreement. If the tokens are an "incentive" or "grant," document this purpose clearly in the recitals of the agreement to prevent them from being characterized as "entrusted" assets.
• Managing Summary Judgment Expectations: Advise clients that summary judgment is difficult to obtain in cryptocurrency disputes where the "intent" of the parties is at the heart of the conflict. If the defendant can point to any credible extrinsic evidence that contradicts the claimant's narrative, the court is likely to grant leave to defend to allow for cross-examination.
• Pleading Counterclaims with Particularity: When seeking to amend a defense to include counterclaims (e.g., for loss of opportunity or reputational damage), ensure they are supported by specific factual particulars. Vague assertions of "loss" without a clear causal link to the claimant's actions are likely to be disallowed as "factually unsustainable" under the ROC 2021.
• Navigating the Parol Evidence Rule: Be prepared to argue the "contextual approach" to contractual interpretation. Even with an entire agreement clause, practitioners should identify specific "surrounding circumstances" that are relevant to the interpretation of technical terms in the crypto space, as these may be admissible under the Evidence Act 1893.
• Costs Submissions: In interlocutory applications under ROC 2021, be prepared for the court to reserve costs and request short, focused submissions. Ensure these submissions directly address the "success" of the application and the conduct of the parties during the proceedings.

Subsequent Treatment

As this judgment was delivered on 4 July 2025, there is currently [None recorded in extracted metadata] regarding its subsequent treatment in later cases. However, given its detailed analysis of summary judgment and amendment principles in the context of digital assets, it is expected to be cited in future cryptocurrency disputes involving the characterization of token transfers and the threshold for "triable issues" under the ROC 2021.

Legislation Referenced

• Evidence Act 1893 (specifically sections 93 and 94 regarding the parol evidence rule)
• Misrepresentation Act 1967 (specifically section 3 regarding the requirement of reasonableness)
• Unfair Contract Terms Act 1977 (specifically section 11 regarding the reasonableness test)
• Rules of Court 2021 (specifically Order 9 Rule 14, Order 9 Rule 16, and Order 9 Rule 17)

Cases Cited

• Applied: [2023] SGHC 216 (regarding the court's discretion to allow amendments at any stage)
• Referred to: [2023] SGHC 223 (regarding the timing of amendment applications)
• Referred to: [2024] SGHC 174 (regarding the principle that terms can only be implied if a contract exists)
• Referred to: [2023] SGHC 335 (regarding the change in legal principles under ROC 2021)
• Referred to: [2023] SGHC 12 (regarding the determination of proper parties to a contract)
• Referred to: Akfel Commodities Turkey Holding Anonim Sirketi v Townsend, Adam [2019] 2 SLR 412 (regarding the power to give summary judgment)
• Referred to: Iskandar bin Rahmat and others v Attorney-General and another [2022] 2 SLR 1018 (regarding the threshold for striking out claims)
• Referred to: The Bunga Melati 5 [2012] 4 SLR 546 (regarding "fanciful" claims)
• Referred to: Broadley Construction Pte Ltd v Alacran Design Pte Ltd [2018] 2 SLR 110 (regarding the principle that parties are not ordinarily bound by extrinsic evidence)
• Referred to: Sembcorp Marine Ltd v PPL Holdings Pte Ltd [2013] 4 SLR 193 (regarding the use of extrinsic evidence in contractual interpretation)
• Referred to: Ritzland Investment Pte Ltd v Grace Management & Consultancy Services Pte Ltd [2014] 2 SLR 1342 (regarding the tactical burden in summary judgment)
• Referred to: AG v Aljunied-Hougang-Punggol East Town Council [2014] 4 SLR 474 (regarding the Quistclose trust model)
• Referred to: Bhoomatidevi d/o Kishinchand Chugani v Nantakumar s/o V Ramachandra [2023] 4 SLR 1644 (regarding the determination of proper parties)
• Referred to: The Luna and another appeal [2021] 2 SLR 1054 (regarding contracts involving undisclosed principals)
• Referred to: Yap Son On v Ding Pei Zhen [2017] 1 SLR 219 (regarding the limits of contractual interpretation)
• Referred to: Wee Cheng Swee Henry v Jo Baby Kartika Polim [2015] 4 SLR 250 (regarding the assessment of a defendant's case for conditional leave)
• Referred to: Peekay Intermark Ltd v Australia and New Zealand Banking Group Ltd [2006] EWCA Civ 386 (regarding the importance of written documents)

Source Documents

• Original Judgment PDF (eLitigation)
• Case Page on eLitigation