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Issues: Whether, while punishing an advocate for contempt of court, the Supreme Court can also suspend or debar the advocate from practice by invoking Articles 129 and 142 of the Constitution, or whether such punishment lies exclusively within the disciplinary jurisdiction under the Advocates Act, 1961.
Analysis: The Court held that the contempt power of the Supreme Court as a court of record is distinct from the statutory disciplinary jurisdiction governing professional misconduct of advocates. The Contempt of Courts Act, 1971 recognises punishments for contempt in the form of imprisonment, fine, or both, and does not create a power to suspend an advocate's licence. The Advocates Act, 1961 provides a separate and complete code for dealing with professional misconduct, including suspension from practice or removal from the roll, through the disciplinary committees of the State Bar Council and the Bar Council of India. Article 142 is a supplementary power intended to do complete justice, but it cannot be used to ignore or supplant the substantive statutory scheme governing advocates' discipline. The Court also held that the appellate power under Section 38 of the Advocates Act cannot be invoked in a contempt proceeding to impose disciplinary punishment in the first instance.
Conclusion: The Court answered the question in the negative and held that, in contempt proceedings, it cannot suspend or revoke an advocate's licence to practice; that power vests exclusively in the statutory disciplinary authorities under the Advocates Act, 1961.
Final Conclusion: The earlier view permitting suspension of an advocate's licence as part of contempt punishment was overruled, and the writ petition was allowed.
Ratio Decidendi: Contempt jurisdiction and disciplinary jurisdiction over advocates are separate and distinct, and the Supreme Court's power under Articles 129 and 142 cannot be used to impose a punishment of suspension from practice where the Advocates Act, 1961 provides an exclusive statutory mechanism for such action.