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Judge: Court of Appeal (Peter Jackson, Coulson and Andrews LJJ)
Citation: [2020] EWCA Civ 1675
The Court of Appeal has had little hesitation dismissing ([2020] EWCA Civ 1675) the appeal by Dahlia Griffith against her conviction and sentence of imprisonment for contempt, on which we reported here. Having applied out of time to appeal and for a stay of the order, which had been refused, Ms Griffith did not appear – indeed, as at the day of the hearing, she had not been found and taken into custody.
Peter Jackson LJ held as follows:
Coulson LJ, agreeing with Peter Jackson LJ, noted that, “[A]lthough the recent changes to CPR Part 81 will do much to make the contempt procedure less cumbersome and complex, there will still be many contempt cases in which a judge will have to roll up his or her sleeves and address in detail not only the facts and the law, but all the many balancing factors necessary to achieve a just outcome.” Sadly, for these purposes, CPR Part 81 does not, in fact, apply to the Court of Protection, its contempt procedures being governed by Part 21 of the Court of Protection Rules 2017, which have yet to be updated in line with the CPR changes which took effect on 1 October 2020.
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