High Court Rules in Contempt of Court Case Involving Unauthorized Recording of Adoption Proceedings

Citation: [2023] EWHC 2966 (Fam)
Judgment on


In the case of ‘His Majesty’s Solicitor General v Jason-Steven: Wong,’ the High Court of Justice has delivered a considered judgment on a matter involving contempt of court. This case, presided over by The Honourable Mr Justice Cobb, scrutinized the actions of the defendant, Jason-Steven: Wong, in the context of adoption proceedings.

Key Facts

Primarily, Jason-Steven: Wong was accused and subsequently found guilty of two salient acts of contempt:

  1. Covertly creating an audio recording of a private court hearing concerning adoption procedures under the Adoption and Children Act 2002.
  2. Disposing of said recording and associated documents, thereby enabling their publication on YouTube.

These acts contravened established privacy laws for family court proceedings, particularly those governing adoption cases, as outlined in section 97 of the Children Act 1989 and section 12 of the Administration of Justice Act 1960. Moreover, Wong carried out these acts with full awareness of their prohibited nature and without regard for the resultant breach of privacy and potential damage to the individuals involved or the integrity of the judicial system.

Several legal principles and precedents provided the framework within which Mr Justice Cobb assessed the case and defined the sanctions:

  • The severity of releasing information about adoption-related court hearings due to the sensitive nature of such proceedings.
  • The Contempt of Court Act 1981, particularly section 14, which guides the court’s discretionary power in sanctioning parties found in contempt.
  • Case precedents such as Liverpool Victoria Insurance Co Ltd v Khan [2019] and HM Attorney General v Crosland [2021], which detail guidelines for determining the appropriate sanction, considering factors like the offender’s culpability, the harm caused, and possible mitigating factors.
  • The significance of ensuring future compliance with court orders and discouraging similar acts of contempt by others, as highlighted in Patel v Patel & O’rs [2017] and endorsed by Hale v Tanner [2000] and Lovett v Wigan Borough Council [2022].
  • Acknowledgment of mitigation factors, including the limited reference to hearing details in the published content, no previous record of similar conduct by the Defendant, and evidence that he took steps to remove the illicit content from YouTube.


Mr Justice Cobb ruled that the Defendant should face custodial sentences for both contempt issues, each set at four months but to run concurrently, hence totaling a four-month term without suspension. The sentence aimed to reflect the severity and deliberate nature of the contempt, as well as its impact on the administration of justice.

Additionally, considering the financial aspects, Cobb LJ awarded costs to the Applicant. The total costs claimed were £30,000, but a submission for £5,000 was deemed reasonable, which the court directed the Defendant to pay, subject to future leave to enforce this order.


In conclusion, the ruling in ‘His Majesty’s Solicitor General v Jason-Steven: Wong’ underscores the obligations of parties involved in family court proceedings to maintain the confidentiality dictated by law. Furthermore, it illustrates the court’s willingness to enforce penalties that correspond with the gravity of the offense and the necessity of a penalty that conveys the court’s disapproval to secure the ongoing compliancy and sanctity of the judicial process. The judgment reaffirms the legal principles that underpin privacy in family law matters, the importance of adequate sanctions in instances of contempt, and the judiciary’s role in upholding these standards.

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