The Judicial Committee of the Privy Council in CL
Financial Ltd (in Liquidation)1 has provided
helpful guidance on applications for approving liquidators'
remuneration. In particular, the JCPC has confirmed that (i) courts
are not required to conduct a line by line analysis of the
liquidator's evidence; (ii) the liquidator's evidence
should be sufficient to provide the court with a clear view of what
the officeholder has done; and (iii) the amount of evidence
provided should be proportionate to the size of the insolvency and
the cost of preparing the information. From a Cayman Islands
perspective, the principles laid down by the JCPC substantially
align with those that have been applied by the Grand Court for more
than two decades. However, as this article notes, there are points
from the decision which may influence remuneration applications in
the Financial Services Division going forward, and which are worth
noting.
