Do H-functions always increase during Violent Relaxation

Recent work on the violent relaxation of collisionless stellar systems has been based on the notion of a wide class of entropy functions. A theorem concerning entropy increase has been proved. We draw attention to some underlying assumptions that have been ignored in the applications of this theorem to stellar dynamical problems. Once these are taken into account, the use of this theorem is at best heuristic. We present a simple counter-example.