A man who recorded part of a private family court hearing centred on his six-year-old daughter on a mobile phone has come under fire from a judge.
Judge Simon Wood said the man might could be in contempt of court if the recording - made at a hearing in Newcastle upon Tyne - was published.
A barrister who had represented the man had alerted the judge to the recording.
She said the man had told her that he had recorded proceedings to "obtain proof" that a social worker had lied.
When questioned the man had said he could not read and had not seen a notice barring recording at a court entrance.
Judge Wood said the man had not co-operated with authorities and the telephone had not been "secured".
The judge had given detail in a written ruling on the case.
He had concluded that the man's daughter should live with relatives.
No-one involved was named but the judge said Gateshead Council had asked him to make decisions about the little girl.