In Amedeo Hotels Ltd Partnership and others v Zaman and others [2007] EWHC 295 (Comm) the court considered an application to discharge a worldwide freezing order on the grounds that the claimants had not disclosed material facts. The court held that there had been an intentional non-disclosure by the claimants. This non-disclosure probably would not have had a material effect on the judge's decision to grant the order. However, it was the "usual course" to set aside the order in such circumstances. The court went on to order that the injunction be reimposed (on terms) as the underlying claims may ultimately belong to an innocent third party. Discharging the order might well deprive them of assets and it was wrong to punish them for non-disclosure by the claimants.

This case is an interesting example of where the court may reimpose an order made without notice where there has been a serious and intentional failure to comply with the duty of full and frank disclosure. It also suggests that the English courts may be more likely to grant interim relief in support of foreign proceedings where such relief would not be available in the primary court.