The Court held that there is no additional requirement in contempt proceedings that all reasonable attempts to effect personal service must be made and failed before substituted service can be ordered. While leave to serve outside Australia was required but not obtained, the defect was cured by the respondent's express submission to jurisdiction. The Court exercised its discretion to allow the contempt trial to proceed in the respondent's absence where he had voluntarily chosen not to attend despite being aware of the proceedings and legally represented.
The full text is available to signed-in members, including the 4 later cases that cite this judgment.