In which case was the significance of 'prima facie' discussed related to freezing orders?

The case of Vaughan v Bonjiorno is significant because it specifically addresses the concept of 'prima facie' in the context of freezing orders, also known as asset preservation orders. In this case, the court explored the necessity for a party seeking a freezing order to establish a prima facie case that they have a legitimate claim against the defendant and that there is a risk of asset dissipation. This means that the applicant must demonstrate sufficient evidence that, if believed, would lead to a favorable judgment in the underlying case.

The significance of establishing a prima facie case in Vaughan v Bonjiorno lies in the protective purpose of freezing orders. The court must be satisfied that there are reasonable grounds to believe that the defendant may dispose of or hide their assets if the order is not granted. This requirement ensures that such an important and invasive order is not issued lightly and is only based on credible claims that warrant such intervention.

This case underscores the importance of demonstrating strong initial evidence to justify the extraordinary relief that a freezing order represents. In this way, Vaughan v Bonjiorno serves as a key reference for understanding how prima facie evidence functions in similar applications for injunctions in Queensland's legal framework.