CONTEMPT, ATTACHMENT AND SEQUESTRATION - appeal from judgment dismissing application to punish litigant for contempt for breach of consent orders - objection to competency of proceedings - whether appeal as of right under s.24(1) of the Federal Court of Australia Act 1976 - whether proceedings constituted proceedings for criminal or civil contempt - treatment of distinction between civil and criminal contempt in Witham v Holloway - [1996] FCA 709 - FCA 1996 case summary — Zoe