In Glenister v. Rowe, supra, reading from paragraph 2, The question in this case is: does a person against whom a costs order may be made have, before an order is actually made, a contingent liability for such costs… and at paragraph 7, …if there were a contingent liability, that was a bankruptcy debt… Reading from paragraph 18 of the judgment of Lord Justice Mummery, where he is quoting from In Re Wisepark,  B.C.C. 221, …a claim for costs is not a truly contingent claim and that it is a claim which comes into existence when the court makes its order for costs. The plaintiff’s submissions
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