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Respondent held in contempt for wilful non‑compliance with a Rule 43(6) order; fresh variation application dismissed for unclean hands.
* Family law – Rule 43(6) – strict interpretation – requires material change subsequent to original order; not a rehearing or appeal.
* Contempt of court – wilful and mala fide disobedience of a Rule 43(6) order – evidentiary burden shifts to respondent to show bona fide inability or reasonable doubt.
* Clean hands principle – non-disclosure, dissipation of funds and obstruction of forensic inquiry disentitle applicant to relief.
* Forensic investigation – duty to provide outstanding documents and cooperate with court-ordered expert.
* Costs – attorney-and-client costs awarded for successful contempt application where appropriate conduct shown.
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