In Chitel v. Rothbart (1982), 39 O.R. (2d) 513,  O.J.
No. 3540 (C.A.), the Ontario Court of Appeal dealt with a refer-
ence directed to them to clarify the jurisprudence as to the
availability of a Mareva injunction in Ontario. It is clear from
Chitel v. Rothbart that the equitable remedy, or a Mareva
injunction, has as its history the English jurisprudence outlined
by the Ontario Court of Appeal in Chitel. Immediately prior to
considering the English case law, the court observed, at para. 30,
The almost exponential growth of the Mareva injunction and the extension
of the grounds for such injunctions, seemingly without regard to long-
established principles, has raised questions, and caused critics to describe
them (as indeed did the Motions Court Judge in the Court below), as being
“tantamount to execution before judgment”. That, strictly speaking, is not
so. What such orders do is tie up the assets of the defendant, specific or
general, pending any judgment adverse to the defendant so that they
would then be available for execution in satisfaction of that judgment. It is
certainly ordering security before judgment.
 The impetus to pursue a Mareva injunction was described
by the Supreme Court of Canada in Aetna Financial Services
Ltd. v. Feigelman,  1 S.C.R. 2,  S.C.J. No. 1, at
para. 25, as follows:
The overriding consideration qualifying the plaintiff to receive [a Mareva
order] is that the defendant threatens to so arrange his assets as to defeat
his adversary, should that adversary ultimately prevail and obtain judg-
ment, in any attempt to recover from the defendant on that judgment.
 As the Court of Appeal noted in Chitel, at para. 31, the
Mareva injunction was “the modern departure” from the “
traditional view in England as well as in this province that an interlocutory injunction would not be granted to restrain a defendant
from disposing of his assets or removing them from the jurisdiction prior to judgment”. The Court of Appeal further noted,
at para. 31, that the “modern departure from that view” had
“its genesis in a trilogy” of cases from England.
 After reviewing the English case law, the court in Chitel
set out, at para. 41, the guidelines established by Lord Denning
in Third Chandris Shipping Corp. v. Unimarine S.A.; The Pythis,
 Q.B. 645,  2 All E.R. 972 (C.A.), as follows:
( i) The plaintiff should make full and frank disclosure of all matters in his
knowledge which are material for the judge to know.
( ii) The plaintiff should give particulars of his claim against the defendant,
stating the ground of his claim and the amount thereof, and fairly stating the points made against it by the defendant.
( iii) The plaintiff should give some ground for believing that the defendants
have assets here.