16.1 The point of the freezing injunction is that the plaintiff proceeds by stealth so as to pre-empt any action by the defendant to remove his assets from the jurisdiction1 or dissipate his assets wherever they are.2 The rationale and fundamental principle is that “no court should permit a defendant to take action designed to frustrate subsequent orders of the court”.3 This principle has been extended to allow the grant of the injunction (as other interim remedies) in connection with proceedings in foreign courts.4