The Chief Constable of Kent Police & Anor v Daryll Sturgess Taylor
[2024] EWHC 813 (KB)
Greg Hazeltine, Re
21 November 2024
[2024] EWHC 2982 (Fam)
High Court
A man was repeatedly rude, abusive, and threatening in family court. Even though he was already in prison for assaulting a judge, the court added more prison time for his bad behaviour because it was unacceptable to threaten and insult judges and disrupt the court. The judge took into account the man's mental health issues but still found the behaviour so serious that further punishment was necessary.
Key Facts
- •Greg Hazeltine was found in contempt of court on nine separate occasions.
- •The contempts occurred during three family court hearings in Milton Keynes in 2023.
- •The allegations included insulting and abusing judges, disrupting proceedings, and threatening behaviour.
- •Mr. Hazeltine had already been sentenced to three years' imprisonment for criminal offences related to three of the contempt allegations.
- •Mr. Hazeltine admitted to the contempt allegations.
- •The judge considered several aggravating and mitigating factors when determining the sentence.
Legal Principles
Contempt of court is an act or omission which creates a real risk of interference with, or prejudice to, the due administration of justice.
Attorney General v Davey [2013] EWHC 2317 (Admin)
In contempt cases, the court should assess the seriousness of the conduct by reference to the offender's culpability and the harm caused, intended or likely to be caused.
HM Attorney General v Crosland [2021] UKSC 15
The principle of double jeopardy applies to civil contempt proceedings.
Jelson (Estates) Ltd v Harvey [1983] 1 WLR 1401 and Re Ramet: Application for Committal for Contempt of Court [2014] EWHC 56 (Fam)
Outcomes
Mr. Hazeltine was found guilty of all nine contempt allegations.
Mr. Hazeltine admitted to the allegations, and the evidence supported the findings.
Mr. Hazeltine was sentenced to an additional five months' imprisonment.
The sentence considered the seriousness of the contempts, aggravating factors (repeated abuse, threats, intimidation), and mitigating factors (admissions, mental health issues, remorse). The sentence was intended to mark the court's disapproval and deter others.