The appellant appealed a trial judgment finding him in civil contempt for breaching a Mareva injunction and sentencing him to 90 days' incarceration, as well as orders for equalization and support.
The appellant argued the contempt proceedings were procedurally unfair and the sentence was disproportionate.
The Court of Appeal dismissed the appeal, finding the trial judge provided adequate assistance to the self-represented appellant, correctly applied the test for civil contempt, and reasonably imposed a custodial sentence given the appellant's chronic non-disclosure, deliberate obfuscation, and flagrant disregard for court orders over 15 years of family litigation.
