In Singularis Holdings Ltd v PricewaterhouseCoopers,1 Lord Neuberger observed, with disarming candour, that “the extent of the extra-statutory powers of a common law court to assist foreign liquidators is a very tricky topic, on which the Board, the House of Lords and the Supreme Court have not been conspicuously successful in giving clear or consistent guidance”.2 After reading the five separate judgments delivered in this recent case, one could be forgiven for thinking that little has changed, though, when the opposing points of departure are as plausible as they have been in these cases, this may be inevitable. On the one hand, it would be surprising if a court in a common law jurisdiction, faced with the practical problems of cross-border insolvency of a magnitude not seen before, was incapable of finding within its principles of private international law the basis for a proper response, but had instead to wait for a legislative solution. One has only to think back to the judicial development of the doctrine of forum non conveniens to see what can be done when a new need arises. On the other hand, where Parliament has legislated to allow