56 In discussing the principles which were applicable, however, Kirby P pointed out that courts of equity have no general duty to enforce the law, including the criminal law, whether at the behest of the Attorney General or any other person with the requisite standing. The primary rule is that the criminal law is enforced by appropriate procedures in the criminal courts - see Peek v New South Wales Egg Corporation, at 2; Gouriet v Union of Post Office Workers [1977] UKHL 5; [1978] AC 435; Commonwealth v John Fairfax & Sons Ltd [1980] HCA 44; (1980) 147 CLR 39 and Meagher, Gummow & Lehane, Equity Doctrines and Remedies, 3rd ed, par 2135. Kirby P, in Peek's case, advanced six reasons why restraint should be exercised in providing injunctive relief where criminal sanctions have not been exhausted. Those reasons led Mackenzie J in Brisbane City Council v Georgeray Contracting Pty Ltd [1995] QSC 57; (1995) 79 A Crim R 265 and Harper J in Pell v National Gallery [1998] 2 VR 391 to refuse applications for an injunction. Mackenzie J noted that proof that there is a deliberate flouting of the law is fundamental in an application of this kind or that the potential consequences of the threatened action are so serious that urgent action is required to stop it. Harper J, in Pell's case, noted in particular that if, in a statutory offence, it had been intended to provide amongst the sanctions enacted the facility of injunctive relief, the legislature could readily have done so.