The High Court today handed down judgment in Manolete Partners plc v White [2023] EWHC 567 (Ch). This is another in a long line of cases about the Court’s jurisdiction to compel a debtor to make good a debt from his pension benefits. In this case, the assignee of a judgment creditor sought an injunction requiring the debtor to draw down his benefits under a SASS in order to pay the debt. The debtor’s principal defence was that s.91 PA 95 precluded the making of such an order. The Judge considered the previous cases, including Blight v Brewster [2012] 1 WLR 2841, Bacci v Green [2022] BPIR 641 and [2023] Pens LR 2, Brake v Guy [2022] EWHC 1746 (Ch) and Lindsay v O’Loughnane [2022] Pens LR 13. The Judge concluded that, although none of these cases had substantively considered the s.91 issue, that section did not preclude the Court from directing that payment of the drawdown benefits be made to a nominated UK bank account in the name of the debtor. This is because the order would not have the effect of restraining the debtor from receiving benefits but rather the opposite: it would ensure that payment of the scheme assets was made to the debtor, rather than remaining within the scheme. It made no difference that the order was motivated by the objective of enabling the scheme assets to be applied in satisfaction of a pre-existing judgment debt owed by the debtor.