In Amedeo Hotels Ltd Partnership v Zaman [2007] EWHC 295 (Comm), the court discharged a freezing order granted without notice on the grounds of serious, intentional non-disclosure by the applicant. The court then reimposed the order, largely to avoid the risk of depriving innocent third parties of assets. For more information, see Legal update, Injunction continued where material non-disclosure was not innocent.

The following practice notes have been updated to mention this decision: Duty of full and frank disclosure, Without notice applications and Freezing injunctions: an overview.