Following an incident of bad behaviour by a defendant in court, a judge was entitled to defer until a later date the issue of whether the defendant was in contempt of court and the issue of punishment for such contempt. The test in Balogh v St Albans (1975) QB 73 regarding a judge's powers to punish summarily for contempt of court had rightly been tempered by Wilkinson v Official Solicitor [2003] EWCA Civ 95 , [2003] 1 W.L.R. 1254.

[2005] EWCA Crim 556