Gelber v Griffin

Gelber v Griffin

Disclosure of Form E documents to Child Support Solutions Limited without court permission constituted contempt of court as CSS did not qualify as a legal representative or professional legal adviser under Rule 10.20A, and the disclosure was not for advice or assistance in relation to the proceedings before the court.

Parties
Applicant: Gelber; Respondent: Griffin
Jurisdiction
England and Wales
Judgment Date
22 November 2006
Procedural Posture
Family Proceedings / Judgment on Notice to Show Cause Regarding Contempt
Outcome
Contempt found; no order made regarding breach.
Legal Topics
Disclosure of Documents, Family Proceedings Rules, Contempt for Breach of Court Rules
Family Law Contempt of Court Disclosure of Documents Family Proceedings Rules Contempt for Breach of Court Rules

Case Brief

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Parties

Gelber

Applicant

Griffin

Respondent

Procedural Posture

Family Proceedings / Judgment on Notice to Show Cause Regarding Contempt

Legal Issues

  1. 1 Whether disclosure of Form E documents to Child Support Solutions Limited without court permission constitutes contempt of court under Family Proceedings Rules

Ratio Decidendi

Disclosure of Form E documents to Child Support Solutions Limited without court permission constituted contempt of court as CSS did not qualify as a legal representative or professional legal adviser under Rule 10.20A, and the disclosure was not for advice or assistance in relation to the proceedings before the court.

Court Disposition

Contempt found; no order made regarding breach.

Orders

  • No order on the breach of Rule 10.20A and contempt.
  • No order as to costs.