English courts may, when making ex parte (without notice) orders in a court-appointed receivership, include a final order that the defendant pays the costs incurred in obtaining the order notwithstanding that it was not notified of the application for the order. Confirming that jurisdiction, the Court of Appeal cautioned that such orders should be made rarely and should include a liberty to the defendant to apply to vary the costs order (and other parts of the order): Bruce Mackay (2) Graham Bushby (Court Appointed Receivers) v Ashwood Enterprises Ltd & 5 Ors [2013] EWCA Civ 959