Criminal contempt through threats to opposing counsel and a qualified apology cannot cure interference with justice.

Threatening notices and disparaging allegations directed at opposing counsel in pending litigation may constitute criminal contempt where they are used to pressure the opposite party or obstruct the free discharge of an advocate's duties, because such conduct interferes with the administration of justice. The court applied the principle that contempt arises when conduct tends to obstruct the judicial process, and treated the notices as contemptuous. It also held that an apology is effective only if it is bona fide, unconditional, timely, and accompanied by real remorse; a qualified or justificatory apology does not erase the contempt or avoid punishment.

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Issues: (i) Whether issuing threatening notices and making disparaging allegations against the opposite party's advocate in a pending proceeding amounts to criminal contempt by interfering with the administration of justice. (ii) Whether the apology tendered by the contemner was bona fide, unconditional, and sufficient to avoid punishment.

Issue (i): Whether issuing threatening notices and making disparaging allegations against the opposite party's advocate in a pending proceeding amounts to criminal contempt by interfering with the administration of justice.

Analysis: Section 2(c)(iii) of the Contempt of Courts Act, 1971 treats as criminal contempt any act that interferes with or tends to interfere with, or obstructs or tends to obstruct, the administration of justice. Applying that principle, the Court held that a litigant cannot pressurize the opposite side or its counsel, or attempt to force withdrawal of pleas by serving notices containing scurrilous, disparaging, or derogatory remarks. Such conduct is not a mere private dispute with counsel; it directly impairs the free discharge of professional duties by an officer of the court and creates an impediment in the judicial process.

Conclusion: The issuing of threatening and disparaging notices to the advocate amounted to criminal contempt and was against the petitioner.

Issue (ii): Whether the apology tendered by the contemner was bona fide, unconditional, and sufficient to avoid punishment.

Analysis: An apology can mitigate contempt only when it is genuine, unconditional, and tendered at the earliest opportunity with real remorse. Here, the apology was coupled with repeated justification of the conduct and fresh allegations against the advocate. The Court treated it as a belated and qualified apology, lacking contrition and not reflecting repentance. Such an apology could not erase the contempt or compel discharge.

Conclusion: The apology was not accepted and did not absolve the contemner.

Final Conclusion: The contemner was held guilty of criminal contempt, punished with simple imprisonment and fine, and the contempt petition was disposed of accordingly.

Ratio Decidendi: Threatening or disparaging an advocate in pending litigation, with the object or tendency of pressurizing counsel or obstructing the conduct of the case, constitutes criminal contempt because it interferes with the administration of justice; a qualified or insincere apology does not neutralize such contempt.

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