R v Huggins [2007] All ER (D) 97 (Jan)
There is no requirement to establish, to prove a contempt of court, an intention to disrupt proceedings. The power of summary punishment is to be exercised only where necessary to protect the process of justice.
The summary procedure should be used only in exceptional cases where contempt is clearly proved and nothing else would do to protect the ends of justice. The decision to imprison a person for contempt should never be taken too quickly and there should always be time for reflection about what is the best course to take.