Interim security for an invoice-based monetary claim pending...

Interim security for an invoice-based monetary claim pending arbitration may be warranted where objective material establishes a strong possibility that the respondent's assets will become insufficient or unavailable for execution. Proof of dishonest intention is not required. A prima facie claim may arise from invoices, correspondence, balance confirmation and payment assurances, while disputes over reconciliation, credit notes and a dishonoured cheque remain for arbitral determination. Audited financial deterioration, negative reserves, substantial liabilities, limited cash, encumbered assets and pending insolvency proceedings may support protective security. Security by deposit or an acceptable bank guarantee preserves the claim without constituting pre-award recovery or deciding liability.