An example of a without notice application for an interim freezing injunction at the pre-action stage. It consists of an application notice (Form N244), an affidavit and a draft freezing order, based on the standard form in CPR Practice Direction 25A. Each document is accompanied by drafting notes.

This case study is illustrative only. The facts are in no way indicative as to whether a court would be minded to grant a freezing order in such circumstances. Great care must be taken to ensure that the facts of a particular case merit the seeking of an injunction in the first place.