However, the position has been illuminated by the decisions since Morgan . It can now be seen that Cross J's interpretation in Phonographic Performance of the word "wilfully" in O 42, r 31 of the Rules of the Supreme Court, 1883 accorded with a proper understanding of what had been said by the English Court of Appeal in Fairclough where the court contrasted "casual, or accidental and unintentional disobedience" with what was required in a case where "it is sought to commit a private individual to prison for contempt" or "to sequestrate the property of a company upon the ground of disobedience" (see, for example, Steiner WLR at pp 991-2; All ER at p 390; Mileage Conference , WLR at pp 1161-2; All ER at pp 861-2; and Flamingo , at p 260). In Steiner Stamp J imposed a fine upon the defendants as punishment for a contempt constituted by breach of an undertaking to the court in a case which was not one which it was "possible to regard as an obstinate disregard" of the undertaking but which was "simply a case of a failure by the company, for no excuse whatever, to carry out the terms of its undertaking" (WLR at p 992; All ER at p 390). In the course of his judgment, Stamp J pointed out (WLR at pp 991-2; All ER at p 390) that the Court of Appeal in Fairclough , in expressing the view that it was necessary, in such cases, that the court's "order has been contumaciously disregarded", was using the word "contumaciously" in the narrow sense of "wilfully". Stamp J expressed the conclusion, in support of which he cited the judgments of Chitty J in Attorney-General at the Relation of the Leyton (Essex) Urban District Council v Walthamstow Urban District Council (1895) 11 Times LR 533 and Warrington J in Stancomb v Trowbridge Urban District Council [1910] 2 Ch 190, that any "disobedience which was worse than casual, accidental or unintentional must be regarded as wilful". His Lordship had earlier indicated that, if the effect of the decision of Stirling J in Worthington was that "nothing short of stubborn opposition to the terms of an order or undertaking amounted to wilful disobedience so as to be punishable by proceedings for attachment", he was not prepared to follow it. In that regard, it is of interest to note that in Mileage Conference (WLR at p 1162; All ER at pp 861-2) the members of the Restrictive Practices Court, who included Megaw J as President and McVeigh LJ, suggested that the approach of Stirling J in Worthington , which they rejected, had resulted from the fact that the only report of Fairclough which had been cited to Stirling J had been "the abbreviated eight-line report in the Weekly Notes and not the fuller and better report in the Solicitors Journal " and that Windeyer J, in Morgan , had likewise referred only to the report of Fairclough in the Weekly Notes when citing that case and Worthington in support of the proposition that conduct which was "wilful, but not contumacious", was not punishable by fine or sequestration. In Mileage Conference , the members of the Restrictive Practices Court (WLR at p 1162; All ER at p 862) accepted as correct the view of the law expressed by Warrington J in Stancomb (at p 194), namely, that it is no answer to proceedings for contempt "to say that the act was not contumacious in the sense that, in doing it, there was no direct intention to disobey the order". Thus, it would suffice that the relevant act or omission was wilful even if, in a case where the breach was constituted by an act or failure to act by a servant or agent, the act or omission of the servant or agent was "through carelessness, neglect, or even in dereliction of his duty" (per Warrington J in Stancomb , at p 194). In Mileage Conference itself, substantial fines were imposed on companies for contempt by breach of undertaking which was not merely non-contumacious but was committed reasonably on legal advice.