The following excerpt is from Gray et al v. Webster et al, 1998 CanLII 6168 (MB CA):
27 In England, where the applicable rule is very similar in its structure to that of Ontario, the courts have indicated that it is not appropriate to get into the merits of the case on an application for security for costs unless it can be clearly demonstrated that there is a high degree of probability of success or failure. See Porzelack KG v. Porzelack (UK) Ltd.,  1 All E.R. 1074 (Ch.Div.).
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