On a private contempt proceeding arising from student strike injunctions, the Court addressed strict procedural and substantive safeguards required before liberty-limiting sanctions may be imposed.
The majority held that contempt notice must clearly identify the alleged offence and that knowledge and intent requirements must be proved beyond a reasonable doubt for the branch relied upon.
On the evidentiary record, the moving party failed to prove actual or inferred knowledge of the specific order and could not sustain liability under the advanced theory.
The acquittal entered by the provincial appellate court was upheld.