JSC BTA Bank v Solodchenko and others [2011] EWCA Civ 1241, [2011] All ER (D) 56 (Nov)
(i) freezing orders were made for good reason and in order to prevent the dissipation or spiriting away of assets. Any substantial breach of such an order was a serious matter which merited condign punishment;
(ii) condign punishment for such contempt normally meant a prison sentence, however, there might be circumstances in which a substantial fine was sufficient; and
(iii) where there was a continuing failure to disclose relevant information, the court had to consider imposing a long sentence, possibly even the maximum of two years, to encourage future co-operation by the contemnor. In the case of continuing breach, out of fairness to the contemnor, the court might see fit to indicate, first, what portion of the sentence should be served in any event as punishment for past breaches and, second, what portion of
