What is the proper burden of proof in civil contempt cases?

Ontario, Canada


The following excerpt is from Zadegan v. Zadegan, 2003 CanLII 49378 (ON SC):

[222] The proper burden of proof in cases of civil contempt is the criminal standard of proof beyond a reasonable doubt: Bhatnager v. Canada (Minister of Employment and Immigration), 1990 CanLII 120 (SCC), [1990] 2 S.C.R. 217 at 224.

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