[2007] EWCA Civ 248

In the absence of unreasonable behaviour a litigant in person who was liable to be sent to prison for contempt of court was entitled to legal representation. Although there would be cases, of which the instant case was an example, where allegations of breaches of an undertaking or court order were relevant to contact proceedings and to committal proceedings, it would seldom be right to hear the proceedings for committal at the same time as the contact proceedings.

CA (Civ Div) (Wall LJ, Moses LJ)

23/03/2007