Noufal Mais v. Maha Shoman

(Saskatchewan) (Civil) (By Leave)


Family law — Financial disclosure — Civil contempt — What are the procedural requirements that must be met before a chambers justice can impose a finding of civil contempt.


Case summaries are prepared by the Office of the Registrar of the Supreme Court of Canada (Law Branch). Please note that summaries are not provided to the Judges of the Court. They are placed on the Court file and website for information purposes only.

The parties were married and have two children. They separated in 2019. The respondent commenced proceedings seeking a divorce, custody, child support, spousal support and an unequal division of family property. In April 2020, the applicant was served with a notice to disclose and notice to file income information. In July 2020, the applicant was ordered to provide disclosure and income information by August 31, 2020. He made partial disclosure on September 1, 2020. At a hearing the following day, the applicant was given one month to provide the additional disclosure. In November 2020, the respondent served a notice asking that the applicant be held in contempt for failure to disclose the materials as ordered. Counsel for the parties appeared in chambers and the applicant was found guilty of civil contempt but applicant could purge his contempt by providing full and proper disclosure by January 30, 2021. The appeal with respect to the contempt finding was dismissed.

Lower Court Rulings

December 18, 2020
Court of Queen’s Bench of Saskatchewan

Div 801/2019 contempt order
Applicant guilty of contempt of court
March 16, 2023
Court of Appeal for Saskatchewan

Appeal with respect to contempt order dismissed