required by Warby J on the particular facts in that case. In that case, unlike the instant case, the action was not taken on behalf of the public at large but a small section of the public where individuals could bring their own private law actions. Further, it was arguable that the injunction sought interfered with Convention rights. 49. In the circumstances of this case, at this stage, there is no reason to depart from the ordinary position and to require the claimants to give an undertaking in damages in this application. However, it is to be noted that if there is to be an application on behalf of individuals to discharge or vary the injunctions, then the court can consider in those cases the extent to which the Article 8 rights of such a person has been interfered with or might be interfered with and whether an undertaking in damages might be required in favour of such a person. The court notes in the Test Valley case before HHJ Dight, for similar reasons as are given above, and recognising that the claimants were public authorities and that the claimants were spending public money and enforcing public rights, that at least at the stage that the injunctions were made, no cross-undertaking as to damages was required.
The Vastint multifactorial test
50. In addition to the test set out in the Wolverhampton case, a question arises as to whether in respect of persons unknown there ought to be considered in addition the particular strictures that exist in relation to precautionary relief, sometimes formerly known as quia timet relief. It is not clear as to the extent to which such relief is greater than the requirements already set out in the Wolverhampton case. The principles in respect of precautionary relief were set out in particular in a case called Vastint Leeds BV v Persons Unknown [2018] EWHC 2456; [2019] 4 WLR 2 at paragraphs 26 to 31, and particularly five propositions which were set out by Marcus Smith J at paragraph 31 of that judgment, which reads as follows:
"21. The manner in which a defendant can be identified other than by name will vary according to the circumstances of the particular case. Three particular instances may be described:
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