The appellant was subpoenaed as a Crown witness at a preliminary inquiry but refused to be sworn and was abusive toward the presiding judge.
The judge convicted him of contempt of court instanter, without notice, a show cause hearing, or an opportunity to consult counsel.
The Supreme Court of Canada allowed the appeal and quashed the conviction, holding that while the judge was justified in initiating summary contempt procedures, there was no urgent and imperative need to forego the usual steps required by natural justice.
