I'm assuming you are in England and Wales - Scotland is different, but I'm not sure exactly in what way. I'm also going to assume that you are talking about hundreds/few thousands of pounds rather than hundreds of thousands (very large amounts of money would make a freezing order seem more reasonable).
There are two parts to your question: can I sue a person even though I don't know his address, and can I enforce that judgement against him later.
You are going to have to serve papers on him somehow. Serving on the last known address is permissible, so you can certainly sue without knowing his current address. (See the Civil Procedure Rules, 6.5(6) at
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). However, if you have any way to serve in person that would be preferable. Similarly if you know his solicitors, and you know they accept service on his behalf, serve papers through them. (Outside of your question I know, but have you tried writing to him care of his bank?)
So far as enforcement is concerned, it sounds as though you are after a Third Party Debt Order rather than a freezing order/Mareva injunction; they would achieve what you wanted if you applied for it
*before* judgement, but they are seriously expensive and heavy handed for what you seem to be after.
Have a look at
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(watch the link wrap). A TPDO would freeze the funds that were in the account when the bank received the order; obviously that may or may not be of use depending on whether the funds are sufficient to pay the debt.
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