A party in contempt of one court (here, the Land and Environment Court) for non-payment of a fine is not precluded from being heard in separate proceedings in another court (here, the Supreme Court) on different issues. The well-established 'same cause' exception applies, and even if the matter is treated as discretionary, the availability of statutory enforcement mechanisms for the fine, the different subject matter of the proceedings, and the absence of defiance of the hearing court's authority all favour permitting the party to be heard. The question whether the principle is a rule subject to exceptions or a matter of discretion remains unresolved.
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