Recent Cases

Grisbrook v MGN

The claimant applied to commit the defendant for breach of an undertaking given in a consent order.  The defendant had undertaken to stop infringing the claimant’s copyright by reproducing the claimant’s photographs in various media.  After giving the undertaking, random checks showed that the defendant was still making available copies of back-publications which included the claimant’s photographs.  Patten LJ refused to commit the defendant: whether the defendant’s activities constituted a breach of the undertaking was a complex point of law and should have been resolved via other means than a committal application.