By Evarist Baimu Nyaga Mawalla - Home

had interfered with the administration of justice and an order for costs could bemade to underline the significance of the if would then be for parliament todeyermine the consequences of that finding. On the facts. The judge inchambers hearing the application for judicial review made on behalf of theapplicant had had jurisdiction to grant an injunction against the Secretarial ofState requiring him to procure the return of the applicant to the jurisdiction of thecourt, notwithstanding that the order was made before he had given the applicantleave to apply for judicial review. The Secretary of State, albeit in his officialcapacity, had properly bveen found to be in contempt in failing to comply withthat order, in failing to keep the judge informed of the situation and in failing toprotect the applicant’s position pending an application to the court to dischargethe order. The appeal would therefore be dismissed (see p 540 d, p 541 a to e, p564 f g, p 567 a to h and p 569 b, post).Dictum of Lord Bridge in Factortane Ltd v Secretary of State for Transport (1989)2 All ER 692 at 708 doubted.Decision of the Court of Appeal (1992) All ER 97 affirmedNotesFor contempt by disobedlence of a court order or breach of an undertaking, see 9Halsbury’s Laws (4 th edn) paras 69, 75, and for cases on the subject see 16Digest (Reissue) 81 –84, 796 – 815.For the Supreme Court Act 1981, s 31. see 11 Halsbury’s starvce (4 th edn( 1991reisse) 991.537