The appointment of special purpose liquidators (SPLs) has become increasingly common, with Courts now readily agreeing to appoint a liquidator who is nominated and funded by a creditor. Those appointments increasingly occur in circumstances where there is no direct conflict or criticism of the general purpose liquidator (GPL), and can be frustrating for the GPL.

Liquidators have a limited time in which to bring proceedings in respect of voidable transactions, generally three years from the relation back day (Limitation Period).[1] However, a Court may grant liquidators a longer period to bring a voidable transaction claim provided the liquidator makes an application for this extension within the Limitation Period itself.