Contempt jurisdiction cannot be used to award costs after substantial compliance with the underlying court order.

Contempt jurisdiction is limited to examining wilful, deliberate and contumacious disobedience of a court order and imposing only the consequence permitted by law. It cannot be used to enlarge the original writ order or to award costs merely because compliance was delayed. Where compliance has been substantially made, the contempt proceedings cannot be kept alive only to justify costs; the limited purpose of the proceedings is then exhausted. The imposition of costs was therefore unsustainable and was set aside, and the contempt proceedings were dropped.

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Issues: Whether costs could be imposed in contempt proceedings for delay in complying with the underlying writ order.

Analysis: Contempt jurisdiction is confined to examining whether there has been wilful, deliberate and contumacious disobedience of a court order and, if so, imposing the statutorily permissible consequence. It cannot be used to enlarge the original order or to impose costs merely because compliance was delayed. Once compliance had substantially been made, the contempt could not be kept alive for the purpose of awarding costs, and the limited purpose of the proceedings stood exhausted.

Conclusion: The imposition of costs in contempt proceedings was unsustainable and was set aside, while the contempt proceedings were dropped.

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