In this post, I attempt to dierentiate between the approaches taken by the Bombay and Delhi High Courts on freezing injunctions. This subject has not received much certainty in commercial disputes despite its popularity in intellectual property rights infringement cases. I attempt to contextualise freezing injunctions within the framework of section 151 read with order 39 rule 1 and 2 of the Code of Civil Procedure (the “Code”) exploring how it is distinct from attachment before judgment (“ABJ”).