In this case, on applicant’s side of the balance is his mere expression of fear that the 3rd respondent, a German, may take the funds of the first respondent out of the country, so that if he wins his appeal, he may not be able to satisfy the judgment. He has not deposed to any steps being taken by the 3rd respondent to take the funds out of the country. The danger is merely feared. It is a quia timet ground for the injunction. Of course this ground has in theory long been established as a valid one for injunctions (for which see Attorney-General v. Long Eaton U.D.C. (1915) 1 Ch.127, p.124). But the condition precedent to a grant of it on quia timet grounds is that the applicant must establish a strong case. For as Lord Dunedin observed, rightly in my view, in Attorney-General for the Dominion of Canada v. Ritchie Contracting and Supply Co. Ltd. (1919) A.C. 999, at p.1005- “But no one can obtain a quia timet order by merely saying ‘Timeo’ he must aver and prove that what is going on is calculated to infringe his rights.”
– Nnaemeka-Agu JSC. Sotuminu v. Ocean Steamship (1992)