The England and Wales Court of Appeal has held that it is sufficient to have a right to institute proceedings as opposed to a cause of action in the strict sense to obtain an injunction. The court gave defendants permission to serve a contribution notice against a fellow defendant and a freezing order in support even though the contribution notice only claimed contingently against the fellow defendant if the applicants were liable on trial: Kazakhstan Kagazy PLC & Ors v Zhunus & Ors  FICR 30
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