The Mareva injunction in Commonwealth jurisdictions, is a court
order which freezes assets so that a defendant to an action cannot
dissipate their assets from beyond the jurisdiction of a court so
as to frustrate a judgment. It is named for Mareva Compania Naviera
SA v International Bulkcarriers SA 2 Lloyd's Rep 509, decided
in 1975, although the first recorded instance of such an order in
English jurisprudence was Nippon Yusen Kaisha v Karageorgis in
1975, decided very shortly before the Mareva decision; however, in
the UK the Civil Procedure Rules 1998 now define a Mareva order as
a "freezing" order. It is widely recognised in other
common law jurisdictions and such orders can be made to have
world-wide effect. It is variously construed as part of a
court's inherent jurisdiction to restrain breaches of its
process.
