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Contempt application preparation

Contempt is a serious application carrying penal consequences — criminal standard of proof applies. This checklist walks through the preparation steps.

In short

This is a 12-step preparation checklist for a contempt application in NSW. It covers elements, standard of proof, evidence and the hearing.

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12-step checklist

The checklist

1

Identify the order breached

Identify the specific order, its terms and the obligations imposed.

Uniform Civil Procedure Rules 2005 (NSW) Pt 55
2

Confirm the order was served

Contempt requires service of the order with a penal endorsement.

Uniform Civil Procedure Rules 2005 (NSW) r 40.7
3

Identify the type of contempt

Civil or criminal contempt, disobedience or interference. Each has different requirements.

4

Gather evidence of breach

Evidence must be admissible and meet the criminal standard — beyond reasonable doubt.

Witham v Holloway (1995) 183 CLR 525
5

Draft the notice of motion

Draft a notice of motion supported by a statement of charge for each alleged contempt.

Uniform Civil Procedure Rules 2005 (NSW) r 55.11
6

Draft supporting affidavit

Detailed affidavit evidence of the breach.

7

Consider less serious remedies

Consider whether a less punitive remedy would suffice — sequestration, costs or further orders.

8

Serve personally

Personal service of the motion and affidavit on the alleged contemnor.

Uniform Civil Procedure Rules 2005 (NSW) r 55.11
9

Brief counsel

Contempt is a serious proceeding — brief experienced counsel.

10

Advise the contemnor of rights

The alleged contemnor has the right to legal representation and to remain silent.

11

Prepare for a defended hearing

Prepare for a full hearing including witness cross-examination and submissions.

12

Plan the orders sought

Draft the orders sought — fine, imprisonment, sequestration, costs.

When to use

When this checklist applies

Use this checklist when an order has been knowingly disobeyed and less serious remedies are inadequate.

Common pitfalls

  • Insufficient evidence of service and knowledge
  • Evidence not meeting the criminal standard
  • Failing to consider alternative remedies
  • Procedural defects in the motion
  • Not advising the alleged contemnor of their rights
Use with Quillio

Run this checklist on a real matter

Quillio drafts contempt motions, statements of charge and affidavits in current NSW format. See /practice-areas/litigation-lawyers.

This checklist is a general guide. Adapt for Federal Court and family law contempt, which have distinct rules.

Use this checklist on your matter.

Quillio can run this checklist on a specific NSW conveyancing matter — confirm each item, calculate adjustments, and generate the supporting documents. The free trial requires no credit card.

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