Mareva or freezing injunction, named after one of the early cases in which such an order was made ( Mareva Compania Naviera SA v International Bulk Carriers SA [1975] 2 Lloyd’s Rep 509); the search order or Anton Piller order, again named after one of the early cases in which such an order was made ( Anton Piller KG v Manufacturing Processes Ltd [1976] Ch 55); the Norwich Pharmacal order, also known as the third party disclosure order, which takes its name from the case in which the basis for such an order was authoritatively established ( Norwich Pharmacal Co v Customs and Excise Comrs [1974] AC 133); the Bankers Trust order, which is an injunction of the kind granted in Bankers Trust Co v Shapira [1980] 1 WLR 1274; the internet blocking order, upheld in Cartier International AG v British Sky Broadcasting Ltd (para 17 above), and approved by this court in the same case, on an appeal on the question of costs: Cartier International AG v British Telecommunications plc [2018] UKSC 28; [2018] 1 WLR 3259, para 15; the anti-suit injunction (and its offspring, the anti-anti-suit injunction), which has become an important remedy as globalisation has resulted in parties seeking tactical advantages in different jurisdictions; and the related injunction to restrain the presentation or advertisement of a winding-up petition. jurisdiction to issue injunctions are not to be cut down by categorisations based on previous practice. In Castanho v Brown & Root (UK) Ltd [1981] AC 557, for example, Lord Scarman stated at p 573, in a speech with which the other Law Lords agreed, that “the width and flexibility of equity are not to be undermined by categorisation”. To similar effect, in South Carolina Insurance Co v Assurantie Maatschappij “De Zeven Provincien” NV [1987] AC 24, Lord Goff of Chieveley, with whom Lord Mackay of Clashfern agreed, stated at p 44: 21. It has often been recognised that the width and flexibility of the equitable
“I am reluctant to accept the proposition that the power of the court to grant injunctions is restricted to certain exclusive categories. That power is unfettered by statute; and it is impossible for us now to foresee every circumstance in which it may be thought right to make the remedy available.”
In Channel Tunnel Group Ltd v Balfour Beatty Construction Ltd (para 19 above) , Lord Browne-Wilkinson, with whose speech Lord Keith of Kinkel and Lord Goff agreed, expressed his agreement at p 343 with Lord Goff’s observations in the South Carolina case. In Mercedes Benz AG v Leiduck [1996] AC 284, 308, Lord Nicholls of Birkenhead referred to these dicta in the course of his illuminating albeit dissenting judgment, and stated :
“As circumstances in the world change, so must the situations in which the courts may properly exercise their jurisdiction to grant injunctions. The exercise of the jurisdiction must be principled, but the criterion is injustice. Injustice is to be
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