High Court Judgment in Contempt of Court Case Emphasizes Importance of Compliance with Court Orders

Citation: [2023] EWHC 2687 (KB)
Judgment on


The case of The Chief Constable of Kent Police & Anor v Daryll Sturgess Taylor ([2023] EWHC 2687 (KB)) provides a comprehensive assessment of the law surrounding contempt of court in the context of breached orders. The judgment, delivered by Mrs Justice Steyn DBE, crystallizes several key legal points that underline the standards for compliance with court orders and the repercussions of non-compliance.

Key Facts

The claimants applied for the committal of the defendant, Mr. Daryll Sturgess Taylor, for contempt of court for breaching court orders stemming from an earlier ‘law of confidence’ claim related to Mr. Taylor’s unauthorized access to certain police videos. Despite the mandatory and prohibitory orders granted against him, Mr. Taylor defiantly chose not to comply with the requirements set by the orders, did not engage with the proceedings meaningfully, and displayed contemptuous behavior toward the legal process through his communications.

Several legal principles emerge from Mrs. Justice Steyn’s judgment, including:

  1. The Standard of Proof: As it was a committal proceeding, the criminal standard of proof applied, requiring the court to be satisfied beyond reasonable doubt before finding contempt of court.

  2. The Requirement of Clarity in Orders: Contempt can only be found if the court order allegedly breached is clear and unambiguous, such as the case with the First Order in paragraph (1)(a) and as varied in the Second Order.

  3. Personal Service of Orders: For contempt to be found, there must be proof that the order was personally served on the defendant unless dispensed with.

  4. Intention and Knowledge: The defendant must have intentionally committed the act or omission constituting the breach, and had knowledge of all the facts making their actions a breach of the order.

  5. Ability to Comply: In the context of a mandatory order, the defendant must have been able to carry out the required acts at the date fixed for compliance.

  6. Behaviour in Contempt Proceedings: The decision to proceed in the absence of the defendant, applying Oliver v Shaikh [2020] EWHC 2253 (QB), underlined that contempt proceedings must be swift and decisive to uphold the justice system.

  7. Penal Notices: The inclusion of penal notices in the orders signals to the defendant the seriousness of non-compliance and inherent consequences of contempt of court.


Justice Steyn found the defendant to be in contempt of court for failing to comply with the mandatory elements of the orders, specifically the requirements laid out in paragraphs (2) and (3) of the First Order (as varied by the Second Order). However, the claim that the defendant was in contempt of court for retaining the Police Videos in breach of paragraph (1)(a) of the First Order was not made out to the criminal standard of proof.

The judgment meticulously deconstructs each allegation of contempt, applying the principles to the facts at hand and reaching conclusions grounded firmly in law, thereby reinforcing the merit of the prohibitory and mandatory orders initially made and underscoring the defendant’s obligations to adhere to them.


In The Chief Constable of Kent Police & Anor v Daryll Sturgess Taylor, the High Court underscores the vital importance of complying with court orders and the severity of consequences for contempt of court. Mrs. Justice Steyn’s judgment reaffirms the legal standards and safeguards in contempt proceedings, emphasizing the rigorous scrutiny required before a finding of contempt can be made. Notably, the case illuminates the stark contrast between deliberate defiance and the impossibility of compliance, distinguishing between the two with legal precision. The judgment delineates the balance between a defendant’s rights and responsibilities within the judicial process, and the inherent powers of the court to compel compliance and sanction non-conformity.