The "Spartacus Order" – The Continuing Saga Of The Persons Unknown Case

In our earlier  case commentary, we have seen how the Malaysian High Court had issued a Mareva injunction and a proprietary injunction against "Persons Unknown" for the first time in Malaysia in a cyber fraud case in Zschimmer & Schwarz GMBH & Co. KG Chemische Fabriken v Persons Unknown and Mohammad Azuwan bin Othman (t/a Premier Outlook Services) [2021] 7 MLJ 178 ("Zschimmer & Schwarz").
 
As a recap, Zschimmer & Schwarz was a case involving a push payment fraud and where the Plaintiff was deceived by the "Persons Unknown" into making payment of approximately €123,014.65 into the 2^nd Defendant's bank account in Malaysia. The owner of the bank account who was identified, was sued as the 2^nd Defendant while the unknown fraudster(s), "Persons Unknown", was sued as the 1^st Defendant.