Home / Cases / His Majesty’s Attorney General v Elavi Dowie [2022] EWCA Civ 1574

His Majesty’s Attorney General v Elavi Dowie [2022] EWCA Civ 1574


His Majesty’s Attorney General v Elavi Dowie [2022] EWCA Civ 1574, [2023] 1 F.C.R. 221, [2023] 3 C.L. 21
Dates of case

Kathryn Howarth successfully represented the Attorney General in proceedings before the Court of Appeal (Lord Justice Bean, Lord Justice Peter Jackson and Lady Justice Asplin). At first instance, Mr Justice MacDonald found Mr Dowie to be in contempt of court for posting recordings and information on You Tube about private family law proceedings involving his children. The Court of Appeal ruled that Mr Dowie could have no possible complaint about his conviction and eight-month sentence but adjusted the costs order on account of Mr Dowie’s means. The Court of Appeal also helpfully noted that there was “considerable force” in the Attorney General’s position that (contrary to the decision in the court below) it was not an element of the mens rea of the category of contempt of court involved that the defendant needed to have an intention to interfere with the course of justice.

Judgment can be viewed here.

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Kathryn Howarth

Call 2005

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Public Law



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