Contempt proceedings under Section 20 begin only when the court forms a prima facie case and issues show-cause notice.

Section 20 of the Contempt of Courts Act, 1971 is triggered only when the court applies its mind to the material, finds a prima facie case of contempt, and decides to commence contempt proceedings by issuing notice to the alleged contemners to show cause why they should not be punished. A private application or an earlier request for notice is only an anterior step and does not amount to initiation. On the facts described, the show-cause notice reflected the court's decision to proceed, so the proceedings were treated as initiated on 6.1.1988 within the one-year period. The order dropping the contempt proceedings was therefore erroneous.

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Issues: Whether contempt proceedings were initiated within the period prescribed by section 20 of the Contempt of Courts Act, 1971 when the court issued notice to the alleged contemners to show cause why they should not be punished for disobedience of the court's order.

Analysis: The expression "initiate any proceedings for contempt" in section 20 means the point at which the court, after applying its mind to the allegations and material, forms an opinion that a prima facie case exists and decides to commence contempt proceedings. A mere application or petition by a private party, or a notice asking why proceedings should not be initiated, is only an anterior step and does not amount to initiation. Initiation occurs when the court calls upon the alleged contemners to show cause why they should not be punished for contempt. On the facts, the order directing notice to show cause why the respondents should not be punished reflected such application of mind and decision to proceed.

Conclusion: The proceedings were initiated on 6.1.1988 within the one-year period under section 20, and the order dropping the contempt proceedings was erroneous.

Ratio Decidendi: Contempt proceedings are initiated for the purposes of section 20 only when the court applies its mind and decides that a prima facie case exists and issues notice to the alleged contemners to show cause why they should not be punished.

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