Solicitor imprisoned for failing to comply with freezing order

On 2 December 2025, Mr Justice Adam Johnson handed down judgment in Sahota & Anor v Newman [2025] EWHC 3174 (Ch) and committed the Defendant Dorota Newman to prison for 12 months for contempt of court. The contempt arose as a result of Newman’s failure to comply with a freezing order.

The underlying claim concerned sums due to the Claimants in relation to the sale of a solicitors’ firm, Jarmans, to Ms Newman. Jarmans was sold by Mr Sahota to Ms Newman under the terms of a Share Purchase Agreement (‘SPA’) dated 3 January 2022. A dispute arose, as Ms Newman failed to make payments pursuant to the SPA, and that dispute was settled in terms contained in a mediation and settlement agreement (the ‘Agreement’) dated 31 August 2023.

Ms Newman failed to make payments pursuant to the Agreement and therefore the Claimants commenced court proceedings against Ms Newman in October 2024. Ms Newman failed to respond to the proceedings and a Default Judgment was obtained against Ms Newman on 12 November 2024, with Master Pester ordering (on 24 November 2025) Ms Newman to pay the combined sum of £498,345 to the Claimants.

Whilst awaiting Master Pester’s determination of the sums due from Ms Newman, the Claimants applied for a freezing order which was granted by Mr Justice Miles in March 2025. The Claimants attempted to personally serve the freezing order on Ms Newman and sent a copy by WhatsApp (as directed by the Court), but Ms Newman ignored all communications and blocked the mobile telephone number in an attempt to evade service. Associated documents in relation to the freezing injunction were also sent by post and email to Ms Newman.

As is normally the case, the freezing injunction required Ms Newman to disclose information about her assets. This requirement had been ignored and formed the basis of an application for contempt of court.

Following a hearing on 3 April 2025, the Court was satisfied (on the evidence before them of the various attempts made to bring the freezing order to Ms Newman’s attention) that Ms Newman had been validly served with the freezing order and thereafter, Mr Justice Marcus Smith dispensed with personal service of both the freezing order and application for contempt which was then emailed to Ms Newman, and sent by Whatsapp, on 15 July 2025.

The hearing of the contempt application was set down for 26 November 2025 but Ms Newman failed to attend and the hearing was adjourned to 2 December 2025. Ms Newman again failed to attend the hearing and Mr Justice Adam Johnson proceeded to hear the contempt application in her absence. Johnson J was satisfied that:

Ms Newman had been served with the pertinent documentation;
Ms Newman had had sufficient notice of the hearing;
There was no reason provided by Ms Newman for her non-attendance;
Ms Newman appeared to waive her right to be present as “the complete lack of engagement with the proceedings from their inception, including at the stage when the Freezing Order was made by Miles J, indicates very strongly that Ms Newman is resigned to the Court proceeding without her attendance or input”;
A further adjournment would not result in Ms Newman attending;
There was limited disadvantage to Ms Newman as “the allegations of contempt are straightforward”;
The “failure by Ms Newman to provide the required information about her assets inhibits enforcement” and the prejudice to the Claimants is continuing and “is more acute now that final judgment has been entered”;
The matter could be dealt with fairly; and
“The overriding objection [was] best served by continuing with the application”.

Mr Justice Adam Johnson found that Ms Newman “knew of her own failure” to disclose her assets as required by the freezing injunction. As a result, the Court found that the breach was serious and that the appropriate sanction would be an immediate sentence to 12 months’ imprisonment to reflect the fact that “the seriousness of the contempt [required] action to be taken now, in part as a deterrent to others”.