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Contempt Of Court - A Comprehensive Analysis

In this research article, I have made an attempt to examine and explain the genesis of the concept of Contempt of Court'. The research will revolve around every aspect attached to this concept including the constitutional provisions regarding the powers to punish, scope of this power, judicial interpretations, etc. The propensity of the judiciary in recent times to frequently exercise its contempt jurisdiction has led to a burning debate on the justifiability of such powers of the court.

The article also throws light on various issues concerning the cases where the authority of the Apex Court has been questioned along with the justifications put forth by the judiciary in its defense. I would also like to clarify that the author doesn't challenge the constitutionality or lawfulness of the contempt jurisdiction of the court.

With utmost respect to the judiciary, the article will be dealing with a comprehensive analysis of the concept of contempt of court'. The main concern of this concept is to protect the administration of justice in criminal as well as civil cases. Being an important and significant area of law contempt of court has been aptly described as the proteus of the legal world.

Introduction
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.[i] 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.[ii] 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.[iii]

The law regarding contempt has been made for preserving the dignity of the courts and keeping the administration of justice properly.[iv] 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 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 court.

The rule of power to punish for contempt of court was laid down in In Re Abdul and Mahtab[v]. 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.

Indian law has divided contempt of court into two sub categories which are civil contempt and criminal contempt. Articles 125 and 215 of the Indian Constitution give the power to the Supreme Court and the High Courts to punish for contempt.

Article 129 of the Constitution defines the Supreme Court as a court of record and it also provides it with the powers to punish for its contempt. A court of Record means a Court whose records are of evidentiary value and can be presented before any Court. This article provides the Apex Court with the power to punish for the contempt of subordinate courts as well.[vi] This jurisdiction of the Supreme Court under Article 129 is independent of the Contempt of Court Act 1971.[vii]

Critical Analysis
The House of Lords, in an important case had formulated the three fold aim of the concept of contempt of Court. The three fold purposes are to enable the parties in litigation be able to come to Court without any third party interference, to enable the courts try their cases without interference and lastly to ensure that the authority and dignity of the courts are maintained.[viii]

Prior to the introduction of contempt of court act in 1926, there were different opinions amongst the High Courts regarding the power to punish for contempt of Subordinate Courts. The Contempt of Court act 1926 was the first act in India regarding contempt. After a few amendments being made to the Act in the following years, it finally got replaced by the Contempt of Court Act of 1971.

This act divided the concept of contempt into two different categories, i.e Civil Contempt and Criminal Contempt. Civil contempt refers to a willful disobedience of any judgement, decree, order, writ, direction or any other process of the court or a willful breach of any undertaking given to the court.[ix] Criminal contempt is the publication of any matter or the commission of any other act which scandalizes or tends to lower the authority of any court, interferes or tends to interfere with the due process of any judicial proceeding or obstructs the administration of justice in any other manner.[x]

The contempt of Courts Act 1971 was enacted with the ultimate purpose of punishing all those persons who in any way, hinder the effective administration of justice or lower the dignity of the Judiciary. The Apex court has also held that the provisions regarding contempt of court under the Indian law are not just for the protection of judges and Courts, they are for the protection of the people.[xi] Everyone is entitled to a free and fair administration of justice.

The Calcutta High Court has observed that the power to punish is arbitrary, unlimited and uncontrolled so it should be exercised with great caution and care.[xii] Now, by the virtue of Article 129 and 215 of the Indian Constitution, both the Supreme Court as well as the High Courts have the power to punish for their contempt and also the contempt of subordinate courts.[xiii] Jurisdiction to punish for contempt is there to formulate ultimate sanction against the person who refuses to comply with the order of the court or disregards the order.[xiv]

There are also a few exceptions which formulate guidelines for reporting on judicial proceedings that do not attract the Contempt provisions. Fair and accurate reporting of a judicial proceeding[xv] or fair comments on the merits of any case which has already been heard by the Court[xvi] are two such exceptions.

There is also a provision that an act would not be punished under contempt unless it substantially interferes or tends to interfere with the due course of justice.[xvii] The period of limitation for initiating the contempt proceedings was also introduced in the Act of 1971 and is provided in Sec.20.[xviii]

The press is also absolutely free to make free and fair criticism and justice should be subject to reasonable public scrutiny. So the press cannot be punished for contempt of court if it is making a free and reasonable criticism of the judgments of the court unless it attacks the integrity of the judges and dignity of the Court.

Important Case-Laws
To know the scope and purpose of the concept of Contempt of Court, it is important to consider and have a look at some of the landmark cases related to it. One such important case is E.M.S. Namboodripad v. T.N. Nambiar[xix]. It was an appeal against conviction for Contempt of Court. It was in regards to a Chief Minister and the utterance he made at a press meeting. Mr. Chief Justice Hidyatullah representing the Apex Court, explained the scope of Contempt of Court observed that:
There are numerous kinds of contempt's.

The central types of disdain are affront to judges, assaults or reasonable remark on pending procedures with an inclination to partiality reasonable preliminary obstacle to officials of the courts, witnesses or the gatherings alongside the procedure of the court, rupture of obligation by official associated with the Court and embarrassing the Judges or then again the courts.

The last structure happens, as a rule, when the direct of an individual will in general bring the specialist and organization of laws into lack of regard or dismissal. This lead incorporated all demonstrations which bring the Courts into offensiveness or lack of regard, or which questions its nobility, insult its greatness or challenge its position."[xx]
In the end, the Apex Court gave a decision upholding the conviction for a Contempt of Court for undermining the dignity and authority of Judiciary.

In another case, the Supreme Court has observed that any defamatory comment against a Judge not concerning whether it is purely administered or even a non-administered matter, amounts to Criminal Contempt.[xxi]

One of the most important discussions regarding the power to punish for contempt of court was held in the case of Arundhati Roy. This happened when the famous writer Arundhati Roy was punished for contempt of Court because of an article written by her called The greater Common Good which also got published in a very famous magazine. The judges held that the article was a misrepresentation of the process of justice and the act came under the ambit of Criminal Contempt.

The motivation behind talking about the above occasions of contempt procedures is positively not to rehash or further the old discussion hovering around the justness of the conviction of Arundhati Roy in the judgement against her.

Contempt Vis-À-Vis Article 19

The concept of criminal contempt of court has been criticized, in relation of it clashing with the fundamental right of freedom of speech and expression guaranteed under Art. 19 of the Constitution of India. This criticism has been given a well sounded and a rational answer in relation of Article 19(1)(a) of the Indian Constitution in the landmark cases of Rustom Cawasjee v. Union of India[xxii] and E.M.S. Namboodiripad v. T.N. Nambiar.[xxiii]

It was held that the Courts do not arbitrarily enjoy immunity from fair criticism. While fair and reasonable criticism is not made actionable, but any attack on the integrity of the Judiciary or improper motives would certainly come under contempt of Court.[xxiv]

The right to freedom of speech and expression given under article 19(2) can't be rehearsed in a manner which offers ascend to the partiality of the court. So, it contains under it arrangement of "Reasonable Restrictions" of which scorn of court is a section.

This is to state that opportunity of articulation isn't an outright idea in itself. In the event when there exist a framework wherein the open confidence can be injured because of obstruction with their trust and confidence in Judiciary, then opportunity of articulation can yield a whole lot of nothing for the vote based system. It is to state that nobody is permitted to distort the foundation of court or any of its procedures or requests which may paint an off-base picture.

Any sort of negative and unfair criticism can break the certainty of the general population. In spite of the fact that the courts have put in endeavour to keep up the objectivity in the way, yet at the same time there has been no particular boundary planned. This zone still smells of vulnerability and uncertainty.

It has also been laid down any publication coming under the ambit of criminal contempt would not be subject to punishment if the publisher had no reasonable grounds to believe that the judgement was still pending.[xxv] It is also a fact that free and fair reporting as well as criticism of the administration of justice is necessary[xxvi] and no action would lie against any criticism which is offered for public good at large.[xxvii]

The conclusion regarding this is that the liberty which is provided under Article 19 of the Indian Constitution should not be abused and unfair criticism of the Judicial System would not be allowed to circumvent the concept of Contempt of Court. It has also been believed that sometimes the distinction between civil contempt and criminal contempt vanishes.

Talking about High Courts, they are the supreme legal authority within a state which enjoys a number of powers even including the power to pronounce a death sentence. [xxviii] It has been provided in the Contempt of Court Act of 1971 under Section 19 that an appeal shall lie as a matter of right from any other order or decision of High Court in exercise of jurisdiction to punish for contempt of Court.[xxix] Any publication which partialities or meddles with the proper working of any legal authority would add up to criminal Contempt of Court.

Media trial or trial by paper isn't viewed as appropriate in light of the fact that it impacts the reasonableness of the trial and is probably going to cause impedance with the authority of the legal system and administration of justice. The punishment for contempt, initially was provided in the act as an imprisonment of a term which may extend to a period of six years, or with a fine amounting to INR 2000 or both.

Section 12 of the Contempt of Court Act 1971 also says that the contemnor could be discharge from the punishment in respect to contempt of Court by an apology for the same made to satisfy the Court.[xxx] It is not a rule that every application of apology will be accepted.

The Court could also reject the application if it thinks that it is not genuine. It has been held in a case that the power provided to the Supreme Court under Article 129 should be sparingly used only when the public interest is concerned.[xxxi]

It is also a fact that contempt is not punishable in each and every case. After the amendment made to the Contempt of Court Act in 2006, Sec. 13 provides that the courts shall impose a sentence under the act only when it is satisfied that it substantially interferes with the due course of justice.[xxxii] It is also a fact that punishment provided is generally more serious and harsh when the contempt takes place in a mofussil area constituting illiterate public.

Provisions have also been formulated regarding the contempt made my judges or any other person acting judicially. This is dealt by Sec. 16 of the Act. The judge of the court could also be held liable for contempt if he/she obstructs the due course of justice or degrades the dignity of the Court.

Limitation

The period of limitation for instituting contempt proceedings has been provided under Sec.20 of the Contempt of Court Act, 1971. It was also observed that the Court has no capacity to broaden the time of limitation as it would by some way or another thrash the arrangement of law. The regular culmination of this would be that after the period, as recommended by Section 20 of the Act, slips by, the jurisdiction would also evaporate under the Act.[xxxiii]

The courts would not be able to exercise jurisdiction after a period of one year from the date of contempt lapses.[xxxiv] There are basically three ways in which contempt proceedings can be initiated. A Suo Motu action can be taken by the Supreme Court or any High Court independently or through a presenting an application to it by a private person.

The attorney general can also take the action and request the Court to start contempt provisions against the contemnor. Applications filed by third persons could also be considered but prior permission from the attorney general is necessary in that case.[xxxv] All these three can only be done if the period of one year limitation has not ended.

Literature Review 1

Scandalising The Fallible Institution-A Critical Analysis Of The Varied Judicial Approach On Criminal Contempt - Rupesh Agarwal [Xxxvi]

This article talks about the concept of criminal contempt of court vis-à-vis the fundamental right of freedom of speech and expression guaranteed by Article 19 of the Indian Constitution. The article has mainly focused on the nature of criminal contempt under the Indian law by at the same time, drawing out a synthesis with the freedom of speech and expression. The powers provided to the Courts to punish for contempt clashes with the right to freedom of speech and expression.

Therefore, a committee was formed in 1961 to cater to this issue at hand and it gave certain recommendations taking note of the importance given to the freedom of speech and expressions. Lord Atkin said that Justice is not a cloistered virtue and it should be allowed to suffer the scrutiny of people even through outspoken comments. [xxxvii] Criminal Contempt is quasi-criminal in nature.[xxxviii] The main aim of having a provision for criminal contempt is to safeguard the Indian Judiciary against any verbal attacks which might injure its reputation or bring down its authority in the eyes of public.

The article has properly explained how the freedom of speech and expression is not made to be exercised to prejudice the authority and proper administration of the Court. The fundamental right provided under Article 19 of the Constitution comes with reasonable restrictions.[xxxix] The article has also drawn a line between Defamation and Contempt.

Literature Review 2

Contempt Of Court: Finding The Limit - Mriganka Shekhar Dutta & Amba Uttara Kak.[Xl]
The aforementioned article talks about the cases and instances when the authority of the Courts regarding the power to punish for contempt has been questioned and the answers and justification of the Judiciary regarding the same.

The article starts with a very famous quote by Justice Jackson from the case of Brown v. Allen[xli] which goes as follows:
We are not final because we are infallible, but we are infallible only because we are final.

Another point which was discussed in this article is that the punishment for contempt could procure submission but not respect. The case-laws talked about in this article show the lack of uniformity in contempt decision resulting in instances of misuse of powers as well as arbitrariness. It was shown properly how the uncertainty was backed up by flexibility provided to the Court. The paper ended with a conclusion that there is no place for the concept of contempt of court in the Modern Judicial system.

Just like the beginning, it ended with a famous quote by Justice Marshal of the Supreme Court of The United States which goes as follows:
Power of judiciary lies neither in deciding cases, nor in imposing sentences, nor in giving punishment for its contempt, but in the trust, confidence and faith of the general public

The article also put forth points that the judges derive their legitimacy and authority from the people and not any king so they should be made answerable to the people as well. The article has also criticized the concept of courts by arguing that the purpose of this concept, which is to uphold the dignity of the Courts in the eyes of public is vague as the Judiciary has created an imaginary self-satisfied image in its own eyes.

The extent of flexibility provided to the provision of Contempt was questioned with due emphasis on the point that the law regarding Contempt is very uncertain in India. The understanding of concept like scandalizing the courts' is constantly changing and rests on subjective interpretations. These were the basic problems regarding the Contempt of Court laws in India which were properly discussed in this article.

Literature Review 3

Review Of The Contempt Of Courts Act, 1971 (Limited To Section 2 Of The Act), Law Commission Of India, Government Of India, Report No. 274, April 2018.
This report has presented a review of the contempt of Court act 1971 in the light of various constitutional provisions and a detailed analysis regarding the same. The report starts with explaining the history of the law regarding Contempt of Court in India by tracing its origins to the East India Company period in India before independence. The report has also explained and cited case-laws and decisions of various judges explaining the importance of the provision of Contempt of Court under the Indian Law.

The constitutional provisions relating to Contempt of Court were properly discussed in the above article by giving due emphasis on Article 19 and its clash with the provisions for Contempt which has already been discussed in the analysis drawn above. Further, various sections of the Contempt of Court Act 1971 have been explained very comprehensively in this report along with case-laws and justifications provided for the same.

The international scenario has also been talked about by explaining the Contempt provisions in various countries such as Pakistan, England, USA, etc. The report has also mentioned the number of contempt proceedings which have been initiated in the Apex Court as well the High Courts as of 2018.

Through this we get to know that still there are a lot of contempt cases which are still pending. In this report, a distinction between a mere technical contempt and the contempt of court has also been drawn out. In case it is just a technical contempt, the court would not be eligible to initiate proceedings. To constitute a contempt of Court, it is necessary that a substantial interference is there with the course of justice.

Recommendations & Conclusion
After looking at the issues relating to the concept of Contempt of Court, I, in the capacity of a law student, with no disrespect intended to the judiciary, would like to present my own recommendations and observations regarding the same.

Under the Constitution, Articles 129 and 215 vest the Superior Courts with the ability to punish for their contempt. Supreme Court and High Courts as to examination and discipline of their contempt, are engaged to explore and punish a contemnor through the powers presented to them by the Articles aforementioned. Furthermore, Article 142(2) additionally empowers the Supreme Court to examine and punish any individual for its Contempt. The Allahabad High Court is having a number of 25370 pending civil contempt cases. Most of the pending cases represent the problems or issued concerned with the uncertain term scandalize the court which has been provided under the Contempt of Court Act 1971.

This is the reason which prompted the United Kingdom to delete the term scandalize the court' under the ambit of criminal contempt. Justice Krishna Iyer has also said that the provisions regarding the Contempt of Court in India are vague and have uncertain boundaries. I am not trying to recommend that the same should happen in India but I think that this uncertainty in law can be removed if the statute is able to provide a proper and comprehensive explanation and definitions of these terms which are the reasons for the uncertainty.

While talking about the clash of this provision with the fundamental right of freedom and speech and expression, I would like to recommend that the flexibility provided to judiciary should be narrowed down and the cases which are reasonable and not having an improper motive should be considered more properly. I would like to say that more importance should be given to the freedom of speech and expression guaranteed as a fundamental right under the Constitution of India.

There have also been other criticisms which are that the judges constantly misuse the powers provided to them and at times act arbitrarily and ruthlessly. What I would like to recommend for this is that a due check should be kept upon the powers of Judiciary in regard of proceedings for contempt and it should be made sure that these powers are sparingly and justly used. In the end I would just like to present my own opinion by taking the side of Lord Atkin when he said that justice is no cloistered virtue. I personally am of the opinion that the administration of justice should be subject to criticism in a fair manner to uphold the rule of law.

The powers provided to the Apex court and the High Courts is very special power which should only be used in rare circumstances. If this power is misused, it could result in curtailing the liberty of the individual by charging him with Contempt of Court. The power should only be used in cases when silence is no longer an option available and the dignity of the court has been undermined as the main purpose behind this law is to keep the administration of justice free from any obstruction or impurity. Although all these problems and uncertainties arise in the implementation of this law but we cannot get rid of this due to the contemptuous elements present in our society.

To ensure Justice in an immaculate way, the judiciary, as the watchman of Rule of Law, is depended with the uncommon capacity to punish wrong and disrespectful behavior planned for undermining its power or bringing its authority into distaste, regardless of whether outside or inside the courts. The law for contempt, with intensity of forcing discipline, guarantees regard for the courts according to people in general by ensuring authorize against lead which may attack the respect of the courts.

The concept of contempt of Court, under the Indian law is to enable the courts to function effectively without any interference or obstruction from outside. It is also important that the dignity and respect of the Judge as well as the Court should be upheld otherwise the people will lose faith in the Judicial procedure.

The very foundation of the judiciary is mostly based on trust of the common people and the concept of Justice will fail if that trust or confidence is lost. It can also be concluded that Contempt provisions under the Indian law are also related to and conflicted with the freedom of speech and expression guaranteed by the Indian Constitution and needs to be understood in respect of the position of the Judiciary in certain important cases which have been discussed in this paper. It is not wrong to say that there is a significant tension between the freedom of speech and expression and the proper administration of justice because of equal importance of both the principles.

The terms provided in the Contempt of Courts Act 1971 such as scandalize the court' or prejudices judicial proceedings' has not been provided proper and accurate definitions which makes the laws regarding contempt in India uncertain and arbitrary in some of the cases. After looking at different observations and judgments it can be said that motives of the Judiciary clashes at one time when it tries to promote the freedom of speech and expression but at the same time does not regard in completeness when it has to care for its own image in the eyes of people. This attempt to multitask has led to an intense and controversial debate regarding the provision of Contempt of Court under the Indian law.

Without a doubt it has been built up that the standard of law can't exist except if there is a rampart of help offered unhinged to the provider of justice, i.e, the Judiciary. It is an intrinsic power vested in the Judiciary to punish any individual who meddles with the administration of justice. It has additionally been built up that the power given to the court isn't to vindicate the nobility of the court but to uphold the dignity of the court and proper administration of law. Hence, we can say if it is justly and properly implemented in reasonable and rare cases, the Concept of Contempt of court is really important for the Indian Judiciary. This can only be said when the powers provided under this particular law is sparingly and properly exercised.

End-Notes:
  1. Arundhati Roy, In Re AIR 2002 SC 1375
  2. MP Jain, Outlines of Indian Legal and Constitutional History(6th Edition,2010)
  3. K. Balasankaran Nair, Law of Contempt of Court in India (2004)
  4. In re: Bineet Kumar Singh, AIR 2001 SC 2018
  5. (8 W.R. Cr. 32)
  6. Delhi Judicial Service Assn. v. State of Gujarat, (1991) 4 SCC 406
  7. Rajeshwar Singh v. Subrata Roy Sahara, AIR 2014 SC 476
  8. Attorney General v. Times Newspapers Ltd., 1974 AC 273
  9. Contempt of Court Act, 1971, Sec. 2 (b)
  10. Contempt of Court Act, 1971, Sec. 2 (c)
  11. Mohomad Yamin v. Om Prakash Bensal, 1982,
  12. Legal Remembrancer v. Matilal Ghose & Ors., (1914) I.L.R. 41 Cal. 173
  13. In Re : Vijay Chandar Mishra, (1995) 2 SCC 603.
  14. Kapildeo Prasad Shah and ors v. State of Bihar and ors., (1999) SCC 569
  15. Contempt of Court Act, 1971, Sec. 4
  16. Contempt of Court Act, 1971, Sec. 5
  17. Contempt of Court Act, 1971, Sec. 13
  18. Contempt of Court Act, 1971, Sec. 20
  19. AIR 1970 SC 2015.
  20. Ibid.
  21. Baradakant v. Registrar, Orissa H.C AIR 1974 SC 710.
  22. AIR 1970 SC 1318
  23. AIR 1970 SC 2015
  24. E.M.S. Namboodiripad v. T.N. Nambiar, AIR 1970 SC 2015
  25. Contempt of Court Act, 1971, Sec. 3(1).
  26. Re Progressive Port and Dock Worker's Union, 1984 Cr LJ 1061 (Ker)
  27. Advocate General v. Abraham Georg, 1976 Cr. LJ 158.
  28. Article 225 of the Constitution of India: Jurisdiction of existing High Courts
  29. Contempt of Court Act, 1971, Sec. 19 (1).
  30. Contempt of Court Act, 1971, Sec. 12 (1).
  31. Hira Lal v. State of U.P, AIR 1954 SC 743
  32. Contempt Of Court Act, 1971, Sec. 13
  33. State of Kerala v. P.K.Ramchandranan (Civil Appeal No. 2485 of 2005) (Ker.)
  34. Dinesh Bhai A. Parek v. Kripalu Cooperative Housing Society, Nagarval Ahmedabad, AIR 1980 Guj. 19
  35. DD Basu, The shorter Constitution of India, 762 (14th Ed.)
  36. Scandalising the fallible institution – a critical analysis of the varied judicial approach on criminal contempt - Rupesh Aggarwal, http://docs.manupatra.in/newsline/articles/Upload/ADE55651-0B73-4CB6-929F-3EBF5392E8D4.1-G__Contempt%20of%20court.pdf
  37. P.N Duda v. P.Shivshanker, AIR 1988 SC 1212.
  38. M.P Jain , Indian Constitutional law, 207 (7th ed. 2010)
  39. INDIA CONST. Art. 19 , cl 2
  40. Contempt of Court: Finding the Limit - Mriganka Shekhar Dutta & Amba Uttara Kak http://docs.manupatra.in/newsline/articles/Upload/8858AB85-A980-4FB5-B726-31B67973DFAB.pdf
  41. 344 U.S. 443 (1953)

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