Also apt is the observation of Blair J. (as he then was) in Surgeoner v. Surgeoner, [1992] O.J. No. 299, that “the need for the sanction of contempt proceedings is of significant importance in the field of family law. There is an undertow of bitterness and sense of betrayal which often threatens to drown the process and the parties themselves in a sea of anger and “self-righteousness”. In this environment it is all too easy for a spouse to believe that he or she “knows what is right”, even after a matter has been determined by the court, and to decide to ignore, disobey or defy that determination. Those who chose to take this tact must know that it will not be tolerated.”
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