Contempt limitation begins on filing or suo motu notice, and fraudulently concealed contempt is timed from discovery.

Proceedings for contempt under section 20 of the Contempt of Courts Act, 1971 are initiated when a contempt application is filed or when the court suo motu commences the matter by issuing notice, not when a later show-cause notice is issued. A special court exercising contempt jurisdiction under section 11A of the Special Court Act must do so consistently with valid procedural law, and limitation is construed harmoniously with that power. Where the contempt is concealed by fraud, limitation runs from discovery of the fraud on principles reflected in section 17 of the Limitation Act, 1963. On the facts, the application was filed promptly after discovery and was within time.

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Issues: Whether proceedings for contempt were barred by limitation under section 20 of the Contempt of Courts Act, 1971, and whether the limitation period began only when the court issued notice or when the contempt application was filed, including the effect of concealment by fraud.

Analysis: The special court under section 11A of the Special Court Act could exercise contempt jurisdiction in the same manner as a High Court under article 215 of the Constitution of India, but that power had to be exercised consistently with a valid procedural law. Section 20 was construed harmoniously with the constitutional contempt power: the expression "initiate any proceedings for contempt" was held to refer to the filing of an application or to suo motu commencement by issuance of notice, and not merely to the stage when the court later issues a show-cause notice. The Court also held that where the facts constituting contempt were concealed by fraud, the principles reflected in section 17 of the Limitation Act, 1963 applied so that time would run only from discovery of the fraud. On the facts, the Custodian learned of the concealment from the income-tax authorities and filed the contempt application promptly thereafter, so the proceeding was within time.

Conclusion: The contempt action was not barred by section 20, and the special court had jurisdiction to proceed on the application filed within limitation.

Ratio Decidendi: For the purposes of section 20 of the Contempt of Courts Act, 1971, contempt proceedings are initiated when an application is filed or when the court suo motu begins the proceeding by issuing notice, and where the contempt is fraudulently concealed, limitation runs from discovery of the fraud.

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