(b) Alongside the historical reasons for limiting the authority to appoint a conference, there are also substantive reasons, which were expressed in case law; this is a far-reaching remedy, in which the defendant's freedom of action in a particular asset is limited by the active actions of the receiver; therefore the receiver should not be made a substitute for bankruptcy proceedings. He may be appointed in the appropriate case only for certain assets, and such a remedy is generally not granted if the plaintiff has effective alternative means; Thus, for example, a court does not appoint a receiver to execute a judgment, where it is possible to appoint a receiver under section 53 ofthe Execution Law, 5727-1967: N. Application for Leave to Appeal 135/81 Inbar v. Inbar, IsrSC 36(1) 169.
(c) In the Bosmat case, this court expanded the scope of Justice Etzioni and held that social, economic and commercial development sometimes justifies the appointment of a receiver, even where in the past it was not possible to make such an appointment. However, he was of the opinion that 'there is no doubt that most of the cases in which a receiver should be appointed are those that fall within the framework of the three categories determined in the Tahoresh case... The essence of the appointment is the preservation of known assets, whether in order to ensure the enjoyment of them, or in order to prevent their removal or destruction, when the methods of execution or other remedies are not useful' (ibid., at p. 293). On the basis of this formulation of the rule and without establishing exhaustive definitions of the issue, the Supreme Court refused to issue a sweeping receivership order on the defendants' assets in the framework of a monetary action, when the plaintiff did not claim rights in certain assets and when the entire purpose of the appointment was to locate assets from which the plaintiff could claim her debt. In the margins of the judgment, Justice Landau also added the following, at p. 296: