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As a matter of construing the R3 Standard Conditions for Individual Voluntary Arrangements, the costs of existing proceedings against a debtor as at the date of the creditors' meeting fell to be treated as a debt provable within the IVA. The deputy judge also passed some observations as to the possibility that the Glenister v Rowe line of authorities as regards costs orders not being a contingent debt being overruled or recast by the Supreme Court in the Nortel litigation.
"This is the ultimate statement of where the law on IVAs is to be found in our great common law...