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Issues: Whether an appeal from an order of the Special Court punishing contempt under the Special Court (Trial of Offences Relating to Transactions in Securities) Act, 1992 lies to the High Court under section 19 of the Contempt of Courts Act, 1971, or only to the Supreme Court under section 10 of the Special Court Act.
Analysis: The Special Court Act was treated as a complete code governing proceedings before the Special Court, including appeals. Section 10 provided that an appeal from any judgment, decree, sentence or order of the Special Court, other than an interlocutory order, lay directly to the Supreme Court both on facts and on law, and section 13 gave the Act overriding effect over inconsistent provisions of other laws. Section 11A conferred contempt jurisdiction on the Special Court by substituting references to the High Court with references to the Special Court, but it did not convert the Special Court into a High Court for purposes of appeal. The absence of an express reference to the Contempt of Courts Act in section 10 did not preserve a High Court appeal when the statutory scheme otherwise confined appeals to the Supreme Court.
Conclusion: An appeal against a contempt order of the Special Court does not lie to the High Court and is maintainable only before the Supreme Court; the present appeals were not maintainable.