“…ay of example, in civil contempt proceedings the criminal standard is conventionally and appropriately applied. As stated by Lord Brown in re D [2008] UKHL 33, [2008] 1 WLR 1499 at p. 1515A, after he had discussed various instances where the criminal standard of proof was applied:…”
“…estly. In doing that, the judge directed himself by reference to the approach to the standard of proof set out by the House of Lords in In re D [2008] UKHL 33; [2008] 1 WLR 1499, and held that even on the test in Ghosh he considered that it was necessary to substitute a finding of dishonesty in relation to charge 5a, and that this conc…”
“…That approach was approved in Re D [2008] 1 WLR 1499, [2008] UKHL 33 although the issue was revisited in re B (Children)(Care Proceedings: Standard of Proof) [2009] 1 AC 11, in which Lord Hoffmann repeated his ea…”