In Emmerson International Corp v Renova Holding Ltd (British Virgin Islands), the Privy Council held that leave is not required to appeal disclosure provisions within a freezing injunction. The Privy Council confirmed the position is the same whether the appeal is in respect of the initial freezing order or a subsequent variation of the order.

The Privy Council made clear that the restraining provisions and the disclosure provisions together form the operative part of a freezing order. It is that operative part, read as a whole, that constitutes an injunction for the purpose of section 30(4)(ii) of the Eastern Caribbean Supreme Court (Virgin Islands) Act, which provides an automatic right of appeal against injunctions.