The CA dismissed the appeal of a serial contemnor – with an unsatisfied judgment debt of more than USD70m – against a two-year custodial sentence. The appellant claimed that the judge had adopted a starting point in excess of the statutory maximum by commenting that his behaviour "merited longer than 24 months". The CA held that there was no absolute rule requiring credit for the Appellant’s admissions of contempt, and the judge was entitled to find them “meaningless” and “lip service” only. Further, the prohibition on the Appellant from leaving the jurisdiction did not amount to mitigation, but rather compliance with an earlier injunction.