Application of rules under old and new CPR 81 in proceedings that began before 1 October 2020 and continue afterwards (High Court)

In Secretary of State for Transport and another v Cuciurean [2020] EWHC 2723 (Ch), Marcus Smith J has added "an important rider" to his judgment in which he found the defendant liable for contempt of court for breaches of an injunction against persons unknown. Acknowledging that his liability judgment straddled two sets of Civil Procedure Rules on contempt because new CPR 81 came into force on 1 October 2020, he clarified why new CPR 81 made no difference to his findings on liability. He then considered the question of sentencing.