In re the Estate of Kramsky

Wingate, S.

The extended research of the court respecting judicial interpretations and applications of section 84 of the Surrogate’s Court Act, in so far as it applies to the enforcement of decrees against non-fiduciary parties by commitment for contempt, has yielded the astonishing result that of the more than five score opinions which have been studied, only four contain any reference to the subject, and all of these statements are purely negative and little better than dicta. This dearth of authority is the more noteworthy by reason of the fact that such situations are continually arising…