What is the common law requirement of service or actual personal knowledge of a court order?

Canada (Federal), Canada

The following excerpt is from Norasia Shipping Services S.A. v. Baltic Marine Agencies Ltd., 2004 FC 183 (CanLII):

The common law has always required personal service or actual personal knowledge of a court order as a precondition to liability in contempt: Bhatnager v. Canada (Minister of Employment and Immigration), 1990 CanLII 120 (SCC), [1990] 2 S.C.R 217 at 225.

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