CHAPTER 1

INTRODUCTION

The whole purpose of adjudication in our adversary system is for a party to explicitly put his

case across the table which will enable the opponent to respond appropriately to that case he

has fielded, and then the Judge, as an impartial umpire will adjudicate on the issues in

controversy. That and nothing more is the epitome of what justice or fair trial is all about.

But the persons playing different roles in this due discharge of Justice is never regarded as

equals in a judicial proceedings. The Judges shall always be superior most, officers of the

court such as persons appointed for examination, commission, receiver etc come next, the

prosecutor and the advocates are the intermediary, the Police and other investigation and

executing branch form the next group, the witnesses and those who give evidence are

regarded next, the petitioner respondent complainant etc lower still, and the defendant

respondent accused etc are the least regarded. Persons appointed for examination,

commission, receiver etc are usually advocates. Thus Bar Bench Relations relate to the

power equations between the top most layers of the functionaries of the judicial process.

The Advocates Act, 1961, provides rules and regulations governing the conduct of advocates

and legal practice. The Act recognises the right of advocates to represent clients before all

courts and tribunals in all states of India. However, an advocate can only register himself in

one State Bar Council but can always transfer his or her name from one State Bar Council to

another. The present Act of 1961 has been enacted to implement the recommendations of the

All India Bar Council Committee, along with the 14th report of the Law Commission in

1955. The purpose of the Act is to outline the qualifications of an advocate, his or her

1
registration and enrolment, provisions for the conduct of advocates, constitution of bar

councils, etc. The Act is divided into 7 chapters, 60 sections and 1 schedule.

The Advocates Act, 1961, received the assent of the President on May 19, 1961 and is

applicable to the whole country. It has been enacted with the objective to:

 Consolidate and amend laws relating to the legal profession and practitioners.

 The Act also aims at constituting the bar council and State Bar Council in each state.

o It also provides powers to the Bar Council of India to make rules and guidelines

in order to regulate the universities involved in teaching law.

The legal recognition to the status of Advocates, their rights privileges as well as duties are

provided under the statutory scheme of the Advocates Act, 1961.

1.1 STATEMENT OF PROBLEM

The problem of the subject is much practical importance in a democratic society like India

where freedom of speech and expression is granted by the constitution. It is possible that

abuse of these freedoms may affect the impartiality and authority of the court and became

detrimental to its dignity. Such abuse is checked by the authority of the use of its contempt

jurisdiction. This seems to be only way to heck the increasing modern tendency to question

the power of all duly appointed authorities. This study is a attempt to see as how this

jurisprudence is being applied particularly by the Indian Judiciary to control the individuals

and other organ of the state without interfering with fundamental and other legal right of the

citizens.

2
1.2 OBJECTIVES OF THE PROJECT:

The project aims to achieve the following:-

 To find out the impact of fair criticism upon independence of judiciary.

 To understand the role of fair criticism in constitutional democracy.

1.3 SCOPE OF THE STUDY

 The study give an overview of fair criticism of the functioning of the judiciary.

 The main intention of the study is to protect the independence of judiciary which is the

main pillar of democracy.

 This study give an overview of the courts power to punish its critics.

1.4 PERIOD

The period of the project starts from September 2024 to October 2024

1.5 LIMITATIONS:

The project suffer from the following limitations:-

 It basically results of individual analysis.

 The sources of the data were limited and the reliability

 Project depends on the reliability of the sources

3
 CHAPTER 2

2. RESEARCH METHODOLOGY

Research is a process in which we gather new facts or present the available facts in a new

way. The quality and value of the research depend upon the proper and particular

methodology adopted for the completion of research work. Legal research is carried on both

for discovering new legal facts and verification of the old ones. The study of Law of

Contempt requires a well planned research methodology to investigate the divergent aspect

of the theme from different angles. This study dealt with doctrinal aspect of the subject.

Under doctrinal legal research analysis of case law, arranging, ordering and systematizing

legal propositions and study of legal institution through legal reasoning have been done.

Doctrinal research is one of the fundamental methodologies of legal research, but

increasingly research looks beyond pure doctrinal analysis. A familiarity with conducting

doctrinal analysis therefore remains fundamental to any legal research project, but most

project will require moving beyond doctrinal analysis to utilize other methodologies. It is

also known as, theory-testing or knowledge building research in the legal academia, it deals

with studying existing laws, related cases and authoritative materials analytically on some

specific matter.

4
 CHAPTER 3

3.SCHEME OF THE STUDY

This study has been divided into seven chapters and the chapter schemes of the study is

given below :

3.1 CONTEMPT OF COURT

We can find the origins of this law in the courts of the monarchs. The monarchs were
believed to be the ones who were directly appointed by the gods and were the sovereign
power of the state. The monarchs were the ones vested with the authority to pass judgement
and provide justice, and interfering with these powers of the monarch was considered to
hinder a divine process.
As the famous Indian polymath wrote in his book Arthashastra “Any person who exposes the
king or insults his council or makes any type of bad attempt on the kings, then the tongue of
that person should be cut off.” And “When a judge threatens, bullies or makes silence to any
of the disputants in the court then he should be punished.”
The Contempt of Court Acts was first introduced in India in 1926. Through the enactment of
The Contempt of Courts 1926, the High courts were vested with the power to penalise any
Contempt against the subordinate courts under their jurisdiction. The Contempt of
Court,1926 was then replaced by The Contempt of Courts Act 1952, which allowed other
courts to penalise the offence of Contempt of Courts High Courts to different courts.
In 1961, a committee was formed under the leadership of H.N. Sanyal, Additional Solicitor
General for the Government of India, to analyse the application of contempt laws in India.
This committee recommended that the courts not initiate the contempt proceedings
themselves, but instead, a law officer should be appointed, on whose recommendations such
proceedings should be initiated.
These recommendations were then incorporated in The Contempt of Courts Act 1971, which
was enacted by the parliament of India, which is the current legislation followed in offences
dealing with the Contempt of courts in India.

3.2 Importance of contempt of court

Contempt in law means being disobedient to a court of law or towards it ruling. The
recognition of contempt of court and to punish for contempt is essential for a nation such as
India which is based on the concept of rule of law, which requires supremacy of law, since
the judiciary is considered, as the last bastion of hope and justice for the citizens of any
nation.

According to the Supreme court bar association vs Union of India (1995), The object of
punishment is both curative and corrective and these coercions are meant to assist an
individual complainant to enforce his remedy and there is also an element of public policy
5
for punishing civil contempt since the administration of justice would be undermined if the
order of any court of law is to be disregarded with impunity.

Contempt of court refers to actions that disrespect or defy the authority of a court. In India,
the Supreme Court and High Courts have the power to punish for contempt, as stated in
the Constitution and the Contempt of Courts Act 1971. This Act categorises contempt into
civil and criminal contempt without defining contempt itself. Civil contempt involves wilful
disobedience of court orders, while criminal contempt includes acts that scandalise the court
or interfere with judicial proceedings. The power to punish for contempt is crucial for
upholding the judiciary’s authority and ensuring the enforcement of court orders.

3.3 THE CONTEMPT OF COURT ACT: HISTORY

The concept of contempt of court is prominent in English law from centuries. Prior to the
coming into force of contempt of courts Act,1926, there existed many conflicts regarding the
concept of contempt of court.

The first contempt law in India was passed in 1926.This act aimed in fulfilling two
objectives :

1. Of removing the doubts regarding the powers of High court Division in punishing
contempt of court; and
2. Of defining and limiting the power of the High Court Division in punishing the
contempt of court.

Punishment of contempt was also mentioned.

This act was repealed by Subsequent act called the Contempt of Court Act,1952.
According to the Act of 1952,

1. Widened the definition of ‘High Court’ to include Judicial Commissioners’s Court;

and
2. Empowered the High Court to intervene in the matter of Contempt for itself ; and for
the subordinate court whether committed within or outside its local jurisdiction ,
committed even by someone who is not subject to the jurisdiction of the courts
mentioned.

A committee was setup under the chairmanship of H.N Sanyal in 1961 to address this
uncertainty in the law and the report was submitted in 1963. Later the contempt of court
Act,1971 was accepted.

6
3.4 Essentials of Contempt of Court

If a person named Akash has to prove that the other person named Sita is guilty of
committing an act which is an offence in a court of law. Then he has to show the court that
the offence which Sita has done is fulfilling the essential required to commit that act or not.
If the essentials of that will be fulfilled then he will be liable for that act. Similarly, every
offence has certain exceptions that has to be fulfilled for making the person liable for doing
that act. Contempt of Court also has certain essentials and these are as follows:

1. Disobedience to any type of court proceedings, its orders, judgment, decree, etc
should be done ‘wilfully’ in case of Civil Contempt.
2. In Criminal Contempt ‘publication’ is the most important thing and this publication
can be either spoken or written, or by words, or by signs, or by visible
representation.
3. The court should make a ‘valid order’ and this order should be in ‘knowledge’ of
the respondent.
4. The action of contemnor should be deliberate and also it should be clearly disregard
of the court’s order.
These essentials should be fulfilled while making someone accused of II.

7
 CHAPTER 4

4.1 ROLE OF CONTEMPT OF COURT IN ETHICS AND ANALYSIS OF

CRIMINAL CONTEMPTS OF THE COURT

The role of ethics in contempt of court, particularly in cases of criminal contempt, is a

complex issue that intertwines legal principles with moral considerations. The concept of
criminal contempt is subjective and broad, often encompassing speech that should be
protected under constitutional rights like free speech and legitimate criticism. The ambiguity
in what constitutes criminal contempt is highlighted by the observation of Fali S. Nariman,
who notes that criminal contempt has fallen out of favour in most civilised countries, yet
remains prevalent in India.
The legal profession is regarded as noble, with advocates acting as officers of the court.
Their adherence to a code of conduct, as outlined in Chapter 2 Part V of the Bar Council of
India rules, ensures the profession’s integrity. These rules emphasise the importance of
maintaining the dignity of the court and ensuring that the actions of advocates do not tarnish
its honour and integrity. Chief Justice Marshall emphasised that the aim of legal ethics is to
uphold the honour and dignity of the legal profession.
However, the lack of specificity in defining acts that harm the dignity of courts and judges
has been criticised. A key question arises regarding whether criticising a judge in a personal
capacity is unethical and scandalises the court’s authority. Dushyant Dave, President of the
Supreme Court Bar Association, differentiated between criticising a judge as a judicial
officer and as an individual, suggesting that the latter should not be seen as contemptuous.
Eminent jurists argue that criticism of judges should not be considered a violation of ethics.
Former Chief Justice Gajendragadkar cautioned against the frequent and indiscriminate use
of the power to punish for contempt, as it could adversely affect the court’s dignity. He
emphasised that justice should be open to scrutiny, a fundamental aspect of democracy.
Suppressing criticism under the guise of contempt can have a chilling effect on free speech.
The higher judiciary’s extensive power in determining what constitutes criminal contempt
has been criticised, especially in cases like that of Advocate Prashant Bhushan. Criticising
judges is seen as a necessary right, with Justice Markandey Katju stating that personal insults
should not impede a judge’s functioning. Arun Shourie and Prashant Bhushan argue that the
concept of scandalising the court’s authority violates the Freedom of speech and is arbitrarily
broad.
The legal threshold for contempt is that it must substantially interfere with the administration
of justice, as outlined in Section 13 of the Contempt of Courts Act, 1971. The Supreme
Court has stated that the exercise of criminal contempt powers is not to protect the individual
judge but to uphold the majesty of the law and the administration of justice.

4.2 CLASSIFICATION:

According to Section 2(a) of the Contempt of Court Act, 1971, contempt of court means
civil contempt or criminal contempt. Section 2(b) of the Act, defines “Civil Contempt” as
8
willful disobedience to any judgment, decree, direction, order, writ or other process of a
court or willful breach of an undertaking given to a court. Section 2(c) of the Act, defines
“Criminal Contempt” as the publication (whether by words spoken or written or by signs or
by visible representations or otherwise) matter or the doing of any act whatsoever which – (i)
Scandalizes or tends to scandalize or lower or tends to lower, the authority of any court, or
(ii) Prejudices or interferes or tends to interfere with, the due course of any judicial
proceeding; or (iii) Interferes or tends to interfere with or obstructs or tends to obstruct, the
administration of justice in any other manner. The above definition contained in the
Contempt of Court Act, 1971, is not exhaustive. It merely indicates that the contempt may be
civil contempt or criminal contempt. It is thus better to leave it to the court to deal with each
case as it comes and a right of appeal under Section 19 of Section the Contempt of Court
Act, 1971, in all cases of contempt will cure whatever defect there may be in the application
of the law.

There are several instances of the misconduct such as using insulting language against the
judge, suppressing the facts to obtain favourable order, imputation of partiality and
unfairness against the judge. A council who advices his client to disobey the order of court is
also held liable for contempt of court. Attacking the judiciary in the bar council election is
taken as contempt of court. If the council refuses to answer the question of the court is also
liable for contempt of court. In Re Ajay Kumar Pandey case1 the Supreme Court held that
advocate using intemperate language against various judicial officers and attributing motives
to them while discharging their judicial function would be held guilty of contempt of court.
In this case such advocate was sentenced or punished to 4 months simple imprisonment and
fine of rupees 1000/-.

4.3 Civil Contempt

Section 2(a) of the Contempt of Court Act, 1971 states Civil Contempt as wilful
disobedience to the order, decree, direction, any judgment or writ of the Court by any person
or wilfully breach of undertakings by a person given to a Court. Since Civil Contempt
deprives a party of the benefit for which the order was made so these are the offences
essential of private nature. In other words, a person who is entitled to get the benefit of the
court order, this wrong is generally done to this person.

The purpose of the proceeding for the civil contempt is not only to punish the contemner but
also to exercise enforcement and obedience to the order of the Court. In Vidya Sagar v. Third
Additional District Judge, Dehradun, 1991 Cr LJ 2286, it was held that Civil Contempt,
actually, serves dual purpose: (i) Vindication of the public interest by punishment of
contemptuous conduct; and (ii) Coercion to compel the contemner to do what the Court
requires of him.

1
2009 AIR SCW 6354
9
To constitute ‘Civil Contempt' the followings are required to be proved: 1. There is
disobedience of the order, decree, etc. of the Court or breach of undertaking given to the
Court; and 2. The disobedience or breach is wilful.

To constitute ‘Civil Contempt' the followings are required to be proved: 1. There is

disobedience of the order, decree, etc. of the Court or breach of undertaking given to the
Court; and 2. The disobedience or breach is wilful. These requirements may be discussed as
follows: 1. Disobedience of the order, decree, etc. of the Court or breach of undertaking
given to the Court: For civil contempt it is necessary that order which has been disobeyed
must have been passed by the Court having jurisdiction to pass order. If the order has been
passed without jurisdiction, it is not binding on the party against which it has been passed
and, therefore, the disobedience of such order will not amount to contempt of Court.1
Further, the burden to prove that the Court which has passed the order had no jurisdiction to
pass it or the proceeding in which the undertaking was given was without jurisdiction lies on
the person who alleges it.

There is a case on the wilful disobedience of court order which a person should know.

Utpal kumar Das vs court of Munsiff, Kamrup2 :This is the case of non-rendering of
assistance, although the court has ordered to render assistance. Decree executed by the court
to deliver immovable property but because of certain obstruction, the defendant failed to do
so. Hence, he was held liable for constituting disobedience to the orders of the competent
Civil Court.

Another case is on the breach of an undertaking which leads to Contempt of Court.

U.P. Resi. Emp. Co-op., House B. Society v. New Okhla Industrial Development Authority
3
In this case, the Supreme Court has directed the Noida Authorities to verify and state on the
affidavit details given by persons for allotment of plots. In pursuance to the same direction
by the Supreme Court a person Mr. S filed a false affidavit to mislead the court. The Registry
directed a show-cause notice against him to say that why an act of contempt should not be
taken against him for misleading the Supreme Court.

In Bhatnagar and Co. Ltd. v. Union of India4, Am 1957 se 478 at pp. 481-482, the court held
that the undertaking must be unconditional, unqualified and express. Where, the party gives
the undertaking to the Court on the basis of certain implications or assumptions which are
false to his knowledge, he will be guilty of misconduct amounting to Contempt of Court.4
What is required to avoid the contempt proceeding is the substantial compliance with the
order of the Court. No court including the Court of contempt is entitled to take frivolities and
trivialities into account while to his knowledge, he will be guilty of misconduct amounting to
Contempt of Court.4 What is required to avoid the contempt proceeding is the substantial
2
AIR 2008 GAU 62

3
1990 AIR 1325
4
1957 AIR 478 1957 SCR 701
10
compliance with the order of the Court. No court including the Court of contempt is entitled
to take frivolities and trivialities into account while finding fault with the conduct of the
person against whom contempt proceeding is taken. If the order is substantially complied
with, the contempt will not lie.

2. Wilful disobedience or breach: For Civil Contempt the disobedience of the order, decree,
etc. of the Court or breach of undertaking given to the Court must be wilful. In India the
Supreme Court6 has, often, pointed out that in order to punish a person or authority for
contempt of Court, the disobedience to any judgment, etc. or breach of undertaking to the
Court must be wilful. Thus, mere disobedience of the order of Court is not sufficient to
constitute civil contempt. The disobedience must be wilful. The disobedience must be
deliberate and intentional. The contempt power cannot be used unless the court is satisfied
beyond doubt that the person has deliberately and intentionally violated the order of the
court.

Whether the disobedience has been wilful, is an issue to be decided by the Court, taking into
account the facts and circumstances of the case. In Ram Narang v. Ramesh Narang 5, the
Court has held that the definition of civil contempt given in section 2(b) creates two
categories of cases: (1) Wilful disobedience to a process of Court; and (2) Wilful breach of
undertaking given to a Court.

As far as the first category is concerned the word "any" further indicates the wide nature of
the power. No distinction has been statutorily drawn between an order passed after an
adjudication and an order passed by consent. This first category is separate from the second
category. The legislative intention has been to distinguish between the two and create distinct
classes of contumacious behaviour. For application of category second the undertaking must
have been given to the Court and not to the other party. The Court has made it clear that
wilful violation of terms of consent decree amounts to contempt of Court. For the
enforcement of decree or direction of the court for payment of money, the contempt
jurisdiction cannot be used. The Court has made it clear that for the enforcement of such
decree or direction the contempt jurisdiction either under the Contempt of Court Act or under
order 39 Rule 2A of the CPC cannot be used

4.4 Defences to Civil Contempt

A person who is accused of Civil Contempt of case can take the following defences:

 Lack of knowledge: A person cannot be held liable for Contempt of Court if he

does not know the order given by the court or he claims to be unaware of the order.
There is a duty binding on the successful party by the courts that the order that has
passed should be served to the Individual by the post or personally or through the
certified copy. It can be successfully pleaded by the contemner that the certified
copy of the order was not formally served to him.
5
1995 SCC (2) 513
11
  The disobedience or the breach done should not be: If someone is pleading
under this defence then he can say that the act done by him was not done wilfully, it
was just a mere accident or he/she can say that it is beyond their control. But this
plead can only be successful if it found to be reasonable otherwise your plead can
be discarded.

 The order that has disobeyed should be vague or ambiguous: If the order passed
by the court is vague or ambiguous or this order is not specific or complete in itself
then a person can get the defence of contempt if he says something against that
order. In R N Ramaul vs Court of Munsiff, Himachal Pradesh [6], this defence has
been taken by the respondent. In this case, the Supreme Court has directed the
corporation of the respondent to restore the promotion of the petitioner from a
particular date in the service. But the respondent has not produced the monetary
benefit for the given period and a complaint was filed against him for Contempt of
Court. He pleads for the defence on the given evidence that it has not mentioned by
the court in order to pay the monetary benefit. Finally, he gets the defence.

 Orders involve more than one reasonable interpretation: If the contempt of any
order declared by the court and the order seems to be given more than one
reasonable and rational interpretation and the respondent adopts one of those
interpretations and works in accordance with that then he will not be liable for
Contempt of Court.

 Command of the order is impossible: If compliance of the order is impossible or it

cannot be done easily then it would be taken as a defence in the case of Contempt
of Court. However, one should differentiate the case of impossibility with the case
of mere difficulties. Because this defence can be given only in the case of the
impossibility of doing an order.
 The order has been passed without jurisdiction.
If the order whose contempt is alleged, has been passed by a court which had no
jurisdiction to pass it, the disobedience or violation would not amount to contempt
of court for the reason that the order passed without jurisdiction is a void order and
binds nobody. In case of Krishna Devi Malchand V. Bombay Environmental
Action Group, the Supreme Court clarified the legal position and held that if the
order is void, it cannot be ignored by the party aggrieved by it. The litigating party
cannot assume the role of Appellate or Provisional authority in order to say that the
order is not binding upon them. Consequently, if any party feels that the order has
been passed by a court which had no jurisdiction to pass it, he should approach the
same court for seeking such declaration by moving an application for recall of the
order. If the application is rejected, the Appellate Court can be approached for such
declaration. In case of State of Jammu and Kashmir vs. Mohd. Yaqub Khan6, the
Supreme Court has held that where stay petition application is pending, the
Contempt Court should not proceed with the contempt case till the stay vacation
application is decided. So, in case of interim order having been passed by a court
which has no jurisdiction, a stay vacation application can be promptly file, raising
6
1968 AIR 765
12
 the plea of lack of jurisdiction.

In Dr. H. Puninder Singh vs. K.K. Sethi7, the Supreme Court has held that if there is
any stay order passed by the Appellate Court, the contempt court cannot proceed.
However, if no interim order application is passed by the Appellate Court, the court
can proceed and the order of the original court should be complied with subject to
any order passed by the Appellate Court at the final stage.

4.5 Criminal Contempt

According to Section 2(c) of the Contempt of Court Act, 1971, Criminal Contempt is
Defined as (i) the publication of any matter by words, spoken or written, or by gesture, or by
signs, or by visible representation or (ii) doing of any act which includes:

1. a) Scandalize or tends to scandalise, or lowers or tends to lower the authority of

any court, or
2. b) Biasness, interferes or tends to interfere with the due course of any type of
Judicial proceedings, or
3. c) obstructs or tends to obstruct, interfere or tend to interfere with the
administration of justice in any manner.
Case on Scandalizing the Court:

Jaswant Singh v. Virender Singh 8

In this case an advocate caste derogatory and scandalous attack on the judge of the High
Court. An application was filed an election petitioner in the High Court, who was an
advocate. He wanted to seek to stay for further arguments in an election petition and also the
transfer of election petitions. These things cause an attack on the judicial proceeding of the
High Court and had the tendency to scandalize the Court. It was held in this case that it was
an attempt to intimidate the judge of the High Court and cause an interface in the conduct of
a fair trial. Thus from the abovementioned definition it can be ascertained that there are four
important essentials to constitute criminal contempt:

1.Publication of any matter.

The word publication has been given a very wide meaning so far as contempt of court is
concerned. It includes words (spoken/written), signs and visible representation. It also
includes the publication of any material in the newspaper and magazines, the broadcasting of
any material on the radio and exhibition of anything in cinemas, theatres and television. If
these materials contain anything which scandalizes or lowers or tends to scandalize or lower
the authority of any court, prejudices or interferes with the due course of any judicial
proceeding or interferes or tends to interfere with administration of justice, it will amount to
criminal contempt of the court.
7
(1998)8SCC640
8
5332(NCE) OF 1993
13
 2. Scandalizing or lowering the authority of the court.

Scandalizing might manifest itself in various ways but in substance, it is an attack on

individual judges in particular or the court as a whole, with or without reference to a
particular case, by casting unwarranted and defamatory aspersions upon the character or the
ability of the judges. Such conduct is punished as criminal contempt for the reason that it
tends to create distrust in the minds of common people and thereby shatters confidence of the
people in the judiciary. The Supreme Court made it clear, in the case of Arundhati Roy 9, that
criticism which undermines the dignity of the court can't be said to be fair criticism and does
not fall under the ambit of freedom of speech and expression as is guaranteed by Article 19
(1)(a) of Constitution of India. Thus prosecution of persons for scandalizing the court is not
prohibited by constitutional right of freedom of speech and expression under Article
1Writing/drafting in pleading or petition by which defamatory allegations have been levelled
against a judge in particular or court as a whole, would amount to criminal contempt, held
the Supreme Court. In case of U.P Residential Employee Cooperative Society v. New Okhla
Industrial Development Authority10, the Supreme Court held that filing a false affidavit in the
court with a view to mislead the court will amount to criminal contempt.

3.Prejudice or interference with the due course of any judicial proceeding.

Any publication which prejudices or interferes with the due course of any judicial
proceeding would amount to criminal contempt of court. Media trial or trial by newspaper is
not considered proper because it effects the fairness of trial and is likely to cause interference
with the administration of justice. The knowledge of pendency of the case and reasonable
grounds to believe that the case in pending is sufficient to make out criminal contempt and
the intention and motive of the publisher behind the content of publication is not relevant for
the purpose of criminal contempt. If it lowers the authority of the court and causes
interference with the due course of judicial proceeding it would amount to criminal
contempt.

In civil cases, the pendency starts with the filing of the plaint and in criminal cases, 9 (1)(a).
with the filing of a charge sheet or the issuance of summons or warrants. The pendency
continues till the case is decided. In case an appeal/revision is filed, pendency continues till
the appeal or revision is decided. If appeal/revision is not filed, pendency continues till the
period of limitation for filing the same has not expired. Once it expires, pendency is over.

4.Interference/Obstruction with the administration of justice in any other manner.

The publication or doing of any act which interferes or obstructs or tend to interfere and
obstruct in the administration of justice in any other manner, would amount to criminal
contempt of court. This clause is a residuary clause, covering those cases of criminal
contempt which are not expressly covered by section 2(c) of the Contempt of Court Act. The
term 'administration of justice' is much wider than the term 'course of judicial proceedings'.
9
2002 AIR (SCW) 1210
10
1990 AIR 1325
14
Every person in India is entitled to approach the court in order to secure justice and for the
redressal of his grievances and the court has to decide dispute between the parties as per law
and equity. Any conduct which tends to prevent or actually prevents a party to approach the
court, amounts to criminal contempt of court, for eg. writing a threatening letter to litigating
party or his counsel preventing him from attending the court, writing a letter to the judge or
approaching him in order to influence his judicial conscience or approaching a counsel for
undue favour are all examples of interference with administration of justice and are contempt
of court. An advocate is an officer of the court and undue interference with the advocate in
the discharge of his professional functions amounts to contempt of court. Casting aspersions
on counsel or approaching him for not defending a particular person amounts to criminal
contempt of court. It was held by the Supreme Court in case of J. R Parashar v. Prashant
Bhushan11, that holding a dharma or resorting to strike by itself may not amount to contempt
of court but if in doing so the presiding officer of the court, its staff, the police personnel and
the litigating parties are prevented from approaching the court, it will amount to interference
in the administration of justice and will be criminal contempt of the court.

4.6 Period of Limitation

Section 20 deals with period of limitation for initiating contempt proceeding. Section 20
provides that no court shall initiate contempt proceedings either on its own notions or
otherwise after the expiry of one year from the date on which contempt is alleged to have
been committed. The period of limitation is applicable both in civil as well as criminal
contempt. Contempt proceedings can be initiated either by filing an application or by the
court itself suo moto. In both the cases, contempt proceedings must be initiated within one
year from the date on which contempt is alleged to have been committed.

In criminal contempt, contempt is alleged to have been committed the moment

scandalization of court or interference with the administration of justice takes place.
Consequently, the period of limitation immediately starts running. But, in case of civil
contempt the period of limitation does not start from the date of the order. It starts running
after expiry of period mentioned in the order after service of certified copy of the order upon
the other side. If no time limit is mentioned in the order, the order should be complied within
a reasonable period. The term reasonable period has been interpreted to be a period of three
months from the date of service of certified copy.

4.7 DEFENCES AGAINST CRIMINAL CONTEMPT

· Innocent publication and distribution of matter.

S.3 deals with this defense. If a criminal contempt is initiated against a person on the ground
that he is responsible for publication or for distribution of publication which prejudices or
11
(2001) 6SCC 735
15
interferes with the pending proceedings, the contemptner may take the following steps:
(a) he may plead under S. 3(1) that at the time of publication, he had no reasonable ground
for believing that the proceeding was pending.
(b) he may plead under S.3(2) that at the time of publication, no such proceeding was
pending.
(c) he may plead under S.3(3) that at the time of distribution of publication, he had no
reasonable ground for believing that the matter (published or distributed by him) contained
or was likely to contain any material which interfered or obstructed the pending proceeding
or administration of justice.

· Fair and accurate report of judicial proceedings

S.4 of the Act provides that a person should not be held guilty of Contempt of Court for
publishing a fair and accurate report of any judicial proceedings or any stage thereof. S. 7 of
the Act provides Exception to the general principle that justice should be administered in
public. Sub sections (1) and (2) of S.7 provide that a person shall not be guilty of Contempt
of Court for publishing the text or for publishing fair and accurate summary of the whole or
any part of the order made by the court in camera (in Chamber) unless the court has
expressly prohibited the publication of the proceedings on the grounds of:
a) Public Policy
b) Public Order
c) Security of the State
d) Information relating to a secret process, discovery or invention, or, in exercise of the
power vested in it.

· Fair criticism of judicial act

S.5 provides that a person shall not be guilty of criminal contempt for publishing any fair
comment on the merits of any case which has been finally decided. A defense can be taken
that the statement complained of (in respect of publication of which criminal contempt has
been initiated) must be in respect of a case which has been finally decided and not in respect
of pending proceedings. Moreover, the statement should come from the mouth of a
knowledgeable person in the field of law and not from a litigating party which has lost the
case. In short, fair criticism means that criticism which while criticizing the act of a Judge
does not impute any ulterior motive to him. In case of Arundhati Roy, the Supreme Court has
held that judicial criticism cannot be invoked under the garb of Freedom of Speech and
Expression under Article 19(1)(a) of the Constitution of India.

The Supreme Court further clarified that fair criticism of the judiciary as a whole or the
conduct of a Judge in particular may not amount to contempt if it is made in good faith and
in public interest. To ascertain the 'good faith' and 'public interest' the Courts have to take
into consideration all the surrounding circumstances including the person's knowledge in the
16
field of law, the intention behind the comment and the purpose sought to be achieved. A
common citizen cannot be permitted to comment upon the Courts in the name of criticism by
seeking the help of Freedom of speech and expression for the reason that if it is not checked,
it would destroy the judicial institution itself.

In the present case, Arundhati Roy was not found to have knowledge or study regarding the
working of the Supreme Court or judiciary of the country and so the defense of fair comment
in good faith and public interest taken by her was rejected and she was punished for criminal
contempt.

· Bonafide complain against the presiding officer of a subordinate court.

S.6 provides that a person shall not be guilty of contempt of court in respect of any statement
made by him by way of complaint in good faith concerning the presiding officer of any sub-
ordinate court to the High Court or to the Court to which he is sub-ordinate. The protection
of this section will be available only when it is proved that the complaint was made in good
faith.

In ascertaining the 'good faith' the intention and the purpose sought to be achieved by
complaint will be taken into consideration and it would be ensured that the same was not
made with ulterior motive.

· No substantial interference with due course of justice.

By the Contempt of Courts (Amendment) Act, 2006, a new Section 13 has been substituted
in place of existing S.13. This new S. 13 provides that notwithstanding anything contained in
any law for the time being in force, no Court should impose a sentence for Contempt of
Court unless it is satisfied that the Contempt is of such a nature that it substantially interferes
or tends to interfere with the due course of justice.

· Justification by truth.
The amended S.13(2) provides that the Court may permit justification by truth as a valid
defence in any proceeding for criminal contempt if it is satisfied that it is in public interest.
Thus, truth is now a defence if it is in the public interest and bonafide.

· The statement complained of is open to different interpretations.

If the words complained of are open to two different interpretations and one of them
indicates contempt while the other does not, the contemptner cannot be punished for non-
compliance of one interpretation. But, in order to succeed in this defence, it is necessary to
prove that the order was complied with in respect of one interpretation. If the order is not
17
complied with at all, it cannot be proved that there was a reasonable doubt as to the
interpretation of the order. On the other hand, it will be presumed that a doubt is deliberately
sought to be created so as to avoid the compliance of the order.

· Defamation of the judge personally.

If the publication or other act is merely a defamatory attack on the judge and is not intended
to interfere with the administration of justice, it will not be taken as contempt of court.

The publication or other Act amounts to Contempt of Court only when it has nexus with the
functioning of a judge. The statement complained of may amount to Contempt of Court only
when it is made against a judge in his judicial capacity in the exercise of his judicial
functions. However, in such a situation a judge is not remediless and he has the same
remedies available which are available to a common man. A defamatory attack on a judge
may be Libel or Slander and he has a discretion to proceed for Defamation in civil, criminal
or simultaneous proceedings against the person concerned but he cannot be punished
summarily under criminal contempt of court. The object of Contempt law is to protect the
confidence of the people in the administration of justice and its object is not to prevent
attacks upon the personal reputation of any individual judge. So, any personal attack upon
the judge unconnected with the office he holds, is dealt with under the ordinary rules of Libel
and Slander.

CHAPTER 5

5.1 CONTEMPT PROCEEDINGS

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Section 14 and 15 of the Act deals with contempt proceedings .

The Section provide that whenever a contempt appears before the Supreme court and the
High court that a person appears to have committed contempt in its presence or hearing the
court may cause such person to be detained in custody, and shall at any time before the rising
of the court on the same day or as early as possible, thereafter :

1. 1.Cause him to be informed in writing of the contempt with which he is charged.

2. 2.Afford him an opportunity to make his defence in respect of the charge
3. 3.After taking such evidence as may be offered by such person and hearing him
proceed either forthwith or after adjournment determine the matter of the charge.
4. 4.Make such order for the punishment or discharge of such person as may be
necessary.

5.2 PUNISHMENT FOR THE CONTEMPT OF COURT

The Supreme court and High courts have the power to punish for contempt of court, either
with simple imprisonment for a term up to 6 months or with fine up to 2000/- or with both.

In 1991, the Supreme court has ruled that if has the power to punish for contempt not only of
itself but also of High courts, subordinate courts and tribunals functioning in the entire
country.

On the other hand, High courts have been given special powers to punish contempt of
subordinate courts, as per section 10 of the Contempt of courts Act,1971

5.3 Remedy Against the Order of Punishment

Following remedies are available against the punishment order under Contempt of
Court Act:

1. Apology:

The contemner may under apology to the court and the court may remit the punishment
awarded for contempt, if the court is satisfied that the apology has been made with real sense
of repentance.
In case of A.K Pandey, the Supreme Court made it clear that the court is not bound to accept
the apology unless there is a feeling of repentance in the contemner. In case of M.C. Mehta
vs. Union of India12, the Supreme Court further clarified that apology should not be used as a
weapon of defense in case of contempt. The apology must be tendered at the earliest
12

19
opportunity. An apology will not be treated as an apology if tendered at a time when court is
going to impose a punishment. However, along with apology the defense taken by contemner
can be pleaded. Explanations to section 12(1) has enabled the contemner to put forward his
defense while pleading apology as this explanation has provided that apology should not be
rejected on the ground that its qualified or conditional if the accused makes it bonafide.
Apology will help the contemner if his explanation has been rejected.

In case of haridas vs Smt. Usharani 13 the apology tendered by contemner was not found to
be genuine as the contemner repeatedly tried to assert that whatever he said was correct and
he would prove it. And at the same time he tender apology. His apology was not found to be
genuine and he was punished for contempt.

2. Appeal:

Contempt of court Act, 1971 has provided for the statutory right of appeal against the orders
of High Court passed in the exercise of its jurisdiction to punish for the contempt of the
court. Prior to this act there was no statutory right of appeal but even at that point of time the
person punished under the Contempt of Court Act was not remediless. The High Court itself
could grant the certificate under Article 134 of the Indian Constitution and where the High
Court refused to grant such certificate, the Supreme Court could entertain the appeal by
granting special leave under Article 136 of the Constitution of India.

So, the right of appeal prior to 1971 was dependent on the discretion of the court and it was
not by the way of right. Section 19(1) of the act provides right of only one appeal. It provides
that an appeal shall lie as of right from any order or decision of the High Court in the
exercise of its jurisdiction to punish for contempt. If the order of punishment has been passed
by single judge of High Court, there is right of appeal to the division bench of not less than
two judges of High Court. If the order of punishment is passed by a division on bench then
appeal will lie in Supreme Court.

However, in case of punishment order passed by single judge, the right of appeal gets
exhausted once the appeal is filed before the division bench and there is no further right of
appeal under the Contempt of Court Act.

However, the remedy under Article 136 of Constitution will still be available and the
Supreme Court may grant leave to appeal under Article 136. Section 19(4) provides for the
period of limitation for preferring an appeal.

It provides that an appeal under Article 19(1) shall be filed within thirty days to the division
bench of High Court and in case the order of punishment has been passed by division bench
of High Court then within sixty days to the Supreme Court from the date of the order
appealed against. Section 19(2) deals with the power of Appellate Court during the pendency
of appeal. It provides that during the pendency of the appeal the Appellate Court may pass
the following orders:

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AIR 2006SC 1634
20
1. The execution of the punishment order shall remain suspended.
2. If appellant is under confinement imprisonment, he may be released on bail.
3. The appeal may be heard notwithstanding that the appellant has not perched his contempt.

Section 19(3) provided that an appeal under section 19 will lie at the instance of the person
aggrieved. A proceeding for contempt is between the court and the contemner. A person who
moves the application for initiating contempt proceeding does not come within the category
of person aggrieved and therefore he has no locus to file an appeal, if his contention for
initiating the contempt proceeding is rejected. If a person is found guilty for contempt of
court, an appeal will lie under section 19 that the instance of person who is found guilty and
is consequently punished. But, if a person is not found guilty of contempt proceedings and
proceedings for contempt is either dismissed or dropped against him then the informant or
person who has moved the application for initiating the contempt will have no right of appeal
under section 19 of the Act. In case of Barda Kant Mishra vs. State of Orissa14, it was
clarified by Supreme Court that the order or the decision of High Court refusing to initiate
contempt proceedings or dropping the contempt proceedings or acquitting the contemner
(even if initiated the contempt proceedings) cannot be challenged by way of appeal under
Section 19. It is only the order of punishment which can be challenged by way of appeal
under section 19 of the act.

The Prashant Bhushan case

In Re. Prashant Bhushan case15, the Supreme Court held Senior Advocate Prashant Bhushan
guilty of Contempt. It held the 2 tweets by the Senior Advocate to be in Contempt of court
because it scandalised the authority of the court. The court relied on the judgement given in
And Others vs. The State Of Uttar Pradesh (1953) in which it ruled that scandalising the
court is when there is an attack on an individual judge or the court as a whole with or without
reference to particular cases, casting unwarranted and defamatory aspersions on the character
of the judges. This according to the court is necessary because it creates distrust in the mind
of the people and “impairs the confidence of people in the courts which is of prime
importance.It further relied on the judgement given in CC,K Dapthary & Ors vs. O. P. Gupta
& Ors (1971)16 in which it ruled that any publication which was calculated to interfere with
the due course of justice or administration of the law would amount to Contempt of Court. It
said that a scurrilous attack on a judge, for a judgement or past conduct, has in our country
the inevitable effect of undermining the confidence of the public in the judiciary and if
confidence in judiciary goes, administration of justice definitely suffers.

• According to the court, the first part of the Tweet stated that, “At a time when he
(Chief Justice) keeps the Supreme Court in lockdown mode, denying citizens the
Fundamental Rights to access to justice.”

14
(1967) ILLJ6630RI
15
(2001) 6SCC 735
16
1971 AIR 1132 1971 SCR 76
21
Court held this to be contemptuous because according to the Court the tweet criticised the
Chief Justice of India in his capacity as the Chief Justice of India and not as an individual.
The court ruled that the tweet had the tendency to shake the confidence of the public in the
Judiciary and this according to the Court undermines the dignity and authority of the
administration of Justice.

It further said that an attack on the Supreme Court not only reduces the confidence of an
ordinary litigant but also of other judges in the country in its highest Court.

 The Court for his 2nd tweet court said that the tweet gives the impression
that the Supreme Court has played a particular role in the destruction of democracy
in the last 6 years and this according to the Court is the criticism of Judiciary as an
institution and shakes the faith of the people in the Judiciary.
The court ruled that an attempt to shake the foundation of Constitutional democracy i.e. the
Judiciary has to be “dealt with an iron hand”. For the Court, the tweets have the effect of
destabilising the Foundation of Indian Democracy.

5.4 Period of Limitation

Section 20 deals with period of limitation for initiating contempt proceeding. Section 20
provides that no court shall initiate contempt proceedings either on its own notions or
otherwise after the expiry of one year from the date on which contempt is alleged to have
been committed. The period of limitation is applicable both in civil as well as criminal
contempt. Contempt proceedings can be initiated either by filing an application or by the
court itself suo moto. In both the cases, contempt proceedings must be initiated within one
year from the date on which contempt is alleged to have been committed.

In criminal contempt, contempt is alleged to have been committed the moment

scandalization of court or interference with the administration of justice takes place.
Consequently, the period of limitation immediately starts running. But, in case of civil
contempt the period of limitation does not start from the date of the order. It starts running
after expiry of period mentioned in the order after service of certified copy of the order upon
the other side. If no time limit is mentioned in the order, the order should be complied within
a reasonable period. The term reasonable period has been interpreted to be a period of three
months from the date of service of certified copy.

CHAPTER 6

6.1 COMPARISION WITH FOREIGN DECISIONS

6.1.A United Kingdom

22
There was no conviction for the offence of Scandalizing the Court from the common law in
England since 1993. The origin of contempt by scandalizing the court can be traced back to
1765. The case of King v. Almon, 17 in which the Almon faced judicial trial against him for
libel against a judge. Justice Wilmort, in this case, gives special punishment to Almon for
libel and from here the scandalizing a court became a form of Contempt of Court. Around a
hundred years later the above case, Lord Morris in the case McLeod v. St. Aubin 18 made a
very wonderful statement that for contempt by scandalizing has become outdated and in
place of that the court should leave on the public opinion whether the attacks or contempt
that are derogatory or scandalous to the Judiciary or not. However, within a year, his words
about the contempt by scandalizing being old or outdated and this has proved false in another
case of Queen v. Grey 19. In this case, it has been conceded by the court that the judiciary is
still open to criticism by the media, but it should qualify the statement “ reasonable
arguments or expostulation” must be offered to treat a statement as a contempt.

6.1.B United States of America

This country has considered the offence of contempt by scandalizing to be too extreme.
Every criticism that we do to the judiciary undermines the authority of the Court. Right to
freely comment or criticise the action of a public institution is of primary importance to the
public and also for the American idea of Democracy. For abolishing the offence of contempt
by scandalizing, the UK consultation paper relied on the landmark decision of the US
Supreme Court decision in case Bridges v. California 20. This offence has been considered
unconstitutional in the United States of America.

6.2 CRITICISM

It is criticized to be reminiscent of British Colonialism in India as the contempt of court laws

have been abolished from the United Kingdom itself. Demands have been raised to restrict
contempt to only Demands have been raised to restrict contempt to only “wilful
disobedience” of directions/judgments of the court and remove “scandalizing the court”.
It is also said that it may lead to judicial overreach. There are high numbers of contempt
cases pending in various High Courts and the Supreme Courts, which delays the justice
administration by an already overburdened judiciary.

Way Forward

Freedom of speech is the most fundamental of the fundamental rights and the restrictions
thereupon have to be minimal. The law of contempt of court can impose only such
restrictions as are needed to sustain the legitimacy of the judicial institutions. Therefore,
rules and guidelines must be framed defining the process that superior courts must employ

17
243, K.B ,1765
18
[1899] A.C.549
19
1900 2 Q.B, 36
20
314 US 252 (1941)
23
while taking criminal contempt action, keeping in mind principles of natural justice and
fairness.

The Contempt of Court clause has been under severe criticism by former judges and lawyers
as it has a negative effect on freedom of speech, being too broad and vague in its definition
and lending scope for its misuse to shield the judiciary from criticisms. In 2011, retired
Supreme Court judge and former Press Council of India Chairman, Markandeya Katju,
called for amendments to the Contempt of Courts Act 1971 to allow the media to report
better on law and judiciary-related matters. In March 2018, the Law Commission of India
was tasked by the Government of India with re-examining Section 2 of the Contempt of
Courts Act 1971, which defines the offence of contempt. The Commission was asked to
examine a proposal that suggested that contempt of court should be limited to cases of civil
contempt, i.e. disobedience of court orders, and should not include the offence of
‘scandalising the court’, i.e. criminal contempt.

6.3 SUGGESTIONS

Contempt of Court or Contempt has been defined as any conduct which tends to disrespect
or overlook the authority of Law and Court. Halsbury has enunciated that contempt consists
of any words, spoken or written which obstruct the course of administration of justice. It
was held by the Apex Court that maintenance of dignity and respect of the Courts is an
important aspect of the principle of rule of law. In India, the concept of contempt of court
could be traced back to pre-independence period during the time of the East India Company
when Mayor Courts were established as Courts of Record. The High Court at Allahabad,
under the Indian High Courts Act 1861 was established as a Court of Record with the power
to punish for contempt. The law regarding contempt has been made for preserving the
dignity of the courts and keeping the administration of justice properly. This law for
contempt, including the powers to punish is for ensuring the respect of the authority of the
Court as well as the Judge in the eyes of people by guaranteeing punishment or sanction
against insult or negative conduct against this authority. The Judiciary is the guardian of rule
of law in India and it needs to be made sure that it is protected with all kinds of problems
that do or might hamper the fluent administration of justice. The provision Fair Criticism and
Independent Judiciary 26 of powers to punish for contempt is significant for ensuring such
respect of the Judiciary. Such kind of power is necessary to prevent interference with the
course of justice and the authority of court27. The rule of power to punish for contempt of
court was laid down in In Re Abdul and Mahtab. The judges may even impose punishments
such as fine or jail term if they believe that contempt has occurred. In India, we have the
contempt of courts act 1971 which defines and limits the court’s powers in punishing
contempt of court and regulates the procedure. Recently, the Supreme Court of India has
held former Ranbaxy promoters guilty of contempt for violating its order. The expression
‘contempt of court’ has not been defined by the Constitution. As per the Contempt of Courts
Act 1971, contempt refers to the offence of showing disrespect to the dignity or authority of
a court. The act divides contempt into civil and criminal contempt. Civil contempt: It is
willful disobedience to any judgment, decree, direction, order, writ or other processes of a
court or willful breach of an undertaking given to the court.
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Criminal contempt: It is any publication which may result in: Scandalising the court by
lowering its authority. Interference in the due course of a judicial proceeding. An obstruction
in the administration of justice. However, innocent publication and distribution of some
matter, fair and reasonable criticism of judicial acts and comment on the administrative side
of the judiciary do not amount to contempt of court. While studying the history of the
Contempt f courts in India, one has to remember that this law originated in pre-independence
India, where the British looked to stifle the criticism of the judicial system by the public.
Though the Contempt of Court Act, 1952 and 1971 have since repealed many of the stifling
provisions of the pre-independence act, some lacunae remain in the law. The Law of
Contempt of Court has to balance the Freedom of right to speech and expression granted to
the citizens of India as well as the provisions made to enable the judicial system to function
without obstruction of any kind. Looking at it from this angle one can immediately realize
that in a democracy the purpose of the Contempt of Court power can only be to enable the
Court to function. The power is not to prevent the people from criticizing the Judges if the
latter do not function properly or commit misconduct. The power given is to prevent
obstruction of justice. The Contempt of Court Act and various proceedings have invited
criticism of the public for being in violation of the provisions of the Constitution. The main
suggestions that have been made in the course of the development of the law are, in the first
place, the correct procedure to punish for offences against the due administration of justice is
to punish such offences as ordinary offences through the ordinary procedure – as far as
practicable. No doubt, this would alter the balance of power between the higher judiciary and
the lower courts as well as the High Courts and the people. Secondly, it is not the case, that
Indian High Courts even possessed the full plenitude of the power of Courts of Record.
Indian Courts of Record had a much more limited power which both before and after the
Constitution could, and can, be disciplined by reasonable restrictions made by the legislature.
Thirdly, there is no impediment to a law being made by the legislature which could cut down
the powers of the High Court to punish for contempt as well as in respect of the procedure to
be followed. No doubt, any such law could not leave the judiciary wholly powerless and
vulnerable28. But, ‘reasonable restrictions’ can be imposed both on the contempt power as
well as on the free speech it seeks to control. Fourthly, India needs to move away from
archaic powers inherited from the common law and try to view the justice system in such a
way that those who promise justice agree to deliver what they promise. It is time that the
shadow on the reform of the law of contempt, to the effect that wide ranging reforms cannot
be made, is lifted. One of the main problems with the law of Contempt of Court was that it
did not allow truth to be a defense. Due to this, constructive criticism as well as real
revelation of corruption in the judiciary could also be held to be contempt of court.

6.4 CONCLUSION
A contempt of court is an offence of civil and criminal character. A man may be sent to
prison for it. It must be satisfactory proved. To use the time-honoured phrase, it must be
proved beyond reasonable doubt.
The basic strategic idea behind such a law is that, people do have the right to criticize judges
but they should not go to the extent of making the functioning of judiciary difficult.

25
Apart from the critisicm there are also some good things about contempt. Contempt of Court
Act,1971 is one of the most powerful statutes in the country. This statute gives the
constitutional court the wide powers to restrict an individual’s fundamental rights to personal
liberty for ‘scandalizing the court’ or ‘willfully disobeying the court’s orders, judgement
decree and discretion, etc.

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7 REFERENCES

STATUTES
 Contempt of Court Act, 1971
 Contempt of Court (Amendment) Act, 2006

WEBSITES
https://blog.ipleaders.in/contempt-of-court- /
https://www.drishtijudiciary.com/editorial/contempt-of-court-in-india#
https://law.uok.edu.in/Files/5ce6c765-c013-446c-b6ac-b9de496f8751/Custom/P.E.
%20unit_5.pdf

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