Does section 996.460 of the vexatious litigant statute, section 391391.7, provide independent statutory authority for a court to award attorney fees as a sanction?

At oral argument, Perry relied upon the vexatious litigant statute itself ( 391391.7) as providing independent statutory authority for the court's award of attorney fees as a sanction, citing Singh v. Lipworth (2005) 132 Cal.App.4th 40 (Singh) as authority. In Singh, the Third Appellate District held that the vexatious litigant statute authorized the trial court to require the plaintiff to post security to pay the defendants' attorney fees without requiring an additional, independent statutory basis. (Id. at pp. 43, 47.) The court concluded that "section 996.460[¹⁰], when read in conjunction with sections 391,

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