In Frith v. Frith, 2008 BCCA 2, Chiasson J.A. outlined that judges should provide an opportunity for the contempt to be purged and address penalty in the context of the degree of affront to the court: at para. 34. Appreciating that such a finding of contempt has not yet taken place, Chiasson J.A. also stated merely obeying a court order after there has been a finding of contempt is insufficient. Relevant to the disposition of a contempt proceeding is a contemnor's acknowledgment that it was an error to disobey the court's order and a commitment to obey in the future.
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