Back Office Ltd v Percival and others [2013] All ER (D) 324 (May)
To succeed in an application for committal for contempt for breach of undertakings, a claimant had to establish to the criminal standard that each of the defendants had broken their undertakings. The court had to be satisfied that the defendants had committed the breaches of undertaking alleged in the application notice and supporting affidavits. A claimant need not prove that a contemnor intended to breach a court order.