jurisdiction . . . in personam against any person, whether an individual or a
corporation, who is, under English procedure, properly made a party to proceedings pending before the English court”.
 Sharpe J.A. also observed that “orders of this kind have
also been made by Canadian courts”, referencing, amongst other
cases, Mooney v. Orr [ B.C.J. No. 2652, 100 B.C.L.R. (2d)
335 (S.C.)], a case considered by Weiler J.A. in in R. v. Consolidated Fastfrate Transport Inc. (1995), 24 O.R. (3d) 564, 
O.J. No. 1855 (C.A.), as set out below.
 The English evolution was described in the U.K. Court
of Appeal decision in Derby & Co. v. Weldon (No. 2), 
2 W.L.R. 276,  1 All E.R. 1002 (C.A.), at para. 6, as follows:
It seems to me that the time has come to state unequivocally that in an
appropriate case the court has power to grant an interlocutory injunction
even on a worldwide basis against any person who is properly before the
court, so as to prevent that person by the transfer of his property frustrating
a future judgment of the court. The jurisdiction to grant such injunctions is
one which the court requires and it seems to me that it is consistent with
the wide words of section 37(1) of the Act of 1981.
In matters of this kind it is essential that the court should adapt the guidelines for the exercise of a discretion to meet changing circumstances and
new conditions provided always the court does not exceed the jurisdiction
which is conferred on it by Parliament or by subordinate legislation.
It remains true of course that the jurisdiction must be exercised with care.
 The concept of a Mareva injunction being an evolving
remedy was also commented on by Weiler J.A. in Consolidated
Fastfrate Transport Inc., at para. 142, as follows:
The practice with respect to the granting of Mareva injunctions is still in
the process of evolving. The early Mareva cases involving foreigners were
simply concerned with the fact that the assets might be removed from Eng-
land and that any judgment granted would be unenforceable. However, in
Barclay-Johnson v. Yuill,  3 AII E.R. 190,  1 W.L.R. 1259 (Ch.
D.) and Prince Abdul Ralman bin Turki Al Sudairy v. Abu-Taha, 
3 AII E.R. 409 (C.A.), injunctions were granted against English nationals as
opposed to foreigners. In Derby & Co. Ltd. v. Weldon [(No. 1) (1988), 
1 All E.R. 469 (C.A.)] a Mareva injunction was granted on a worldwide basis
on the condition that certain undertakings were given by the applicant
which would protect the defendant from oppression and misuse of infor-
mation and protect the position of third parties. Most recently, Mooney v.
Orr, B.C.S.C., November 24, 1994 (unreported, Vancouver Registry
No. C908539) [now reported 100 B.C.L.R. (2d) 335,  3 W.W.R. 116],
Huddart J. granted a worldwide Mareva injunction against Mooney, who,
prior to entering into business dealings with the Orrs, had so arranged his
affairs as to protect any offshore property he might have from execution.
Huddart J. cited the decision of the British Columbia Court of Appeal
in British Columbia (Attorney General) v. Wale (1986), 9 B.C.L.R. (2d) 333 at
p. 346,  2 W. W.R. 331 (C.A.), where McLachlin J.A. said: