On 8 July 2026, the High Court has made a committal order in DBLP Sea Cow Ltd v Steffensen [2026] EWHC 1735 (Ch), committing the Defendant, Mr Steffenesn, to prison for the maximum two-year sentence, for repeated and deliberate refusals to comply with court injunctions.
David Reade KC and Alexander Halban acted for the Claimant, instructed by Richard Viegas and Jennifer Gregor of Winston Taylor International LLP. Alexander Halban had acted for the Claimant throughout the proceedings. Mellor J commented on the ‘very comprehensive and useful Skeleton Argument prepared by Counsel for DBLP’.
The case involved shares in Rezolve AI plc, an AI company listed on the NASDAQ. The Claimant, DBLP agreed to sell the shares to Mr Steffensen under a share purchase agreement. The agreement required Mr Steffensen to hold the shares on trust for DBLP pending full payment of sum due under the SPA and, if he failed to pay, he had to return the shares.
Instead, Mr Steffensen sold the shares, in breach of trust, and spent the sale proceeds. He did so using a sham version of the SPA which he showed his broker to persuade them to release restrictions on the shares.
Rajah J granted DBLP a proprietary injunction ([2025] EWHC 2732 (Ch)), freezing the shares and sale proceeds, and ordering Mr Steffensen to disclose their location. Mr Steffensen refused to identify the recipients of the payments which he made out of the sale proceeds, and also refused to give his bank details, in breach of the injunction.
DBLP obtained a further injunction from Mellor J ([2025] EWHC 2983 (Ch)) ordering more detailed information to locate the share sale proceeds. Mr Steffensen again refused to provide that information, in breach of that injunction.
Finally, DBLP obtained an ‘unless’ order from Sir Anthony Mann, that if Mr Steffensen refused to comply with these court orders, he would be debarred from defending the claim. Mr Steffensen again refused to comply and was debarred.
DBLP obtained summary judgment on the claim for $7 million ([2026] EWHC 281 (Ch)). The court made a further injunction requiring Mr Steffensen to reveal the location of the sale proceeds. Mr Steffensen failed to comply with that order either.
DBLP brough contempt proceedings against Mr Steffensen for his breaches of these court orders. Mr Steffensen had solicitors on the record but did not defend the proceedings or attend the committal hearing.
Mellor J proceeded in Mr Steffensen’s absence. On liability, Mellor J found that
- Mr Steffensen actively knew of all four orders (and so Mellor J waived the requirement for personal service of the orders);
- Mr Steffensen acted in breach of the injunctions;
- Mr Steffensen knew of his actions which amounted to a breach of the Injunction.
Mellor J went further and was satisfied beyond reasonable doubt that Mr Steffensen intended to breach the orders, which was relevant to sentence.
On sentence, Mellor J found that ‘Mr Steffensen’s contempts are at the highest level of seriousness and they are continuing… it is clear that Mr Steffensen had no intention of complying with his obligations under the SPA he sham SPA he used to show his broker and which enabled him to sell the shares was all part of a plan effectively to steal the valuable shares […] sell them and appropriate all the proceeds. Mr Steffensen’s breaches of each of the four Orders represented a continuation of that strategy, designed to prevent DBLP from recovering any of the Sale Proceeds of the shares’
The contempts to be ‘entirely deliberate and flagrant’ and his attitude to each order was ‘scornful and insolvent’. Mellor J sentenced Mr Steffensen to the maximum two years’ imprisonment permitted by law. He refused to suspend the sentence since the seriousness of the contempts required immediate action, although it remained open to Mr Steffensen to attempt to purge his contempt.
The contempt judgment can be found here.
The summary judgment can be found here.
The injunction judgment can be found here.
The further injunction judgment can be found here.
