Recusal and contempt principles: unsubstantiated allegations cannot force recusal, and scandalous pleadings may trigger protective action.

Recusal requires a real conflict of interest or personal disqualification, not unsubstantiated allegations raised after adverse orders. On the facts discussed, allegations against the Judge and Registry arose from official acts in earlier proceedings, and no ground for recusal was made out. The text also states that wild, reckless and scurrilous allegations in pleadings and publications, coupled with attempts to browbeat the Court and secure favourable orders through false proceedings, may amount to abuse of process and contempt. The Court accordingly proceeded to initiate contempt action, frame draft charges, and impose interim protective restraints pending further consideration.

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Issues: (i) Whether the applicant's plea for recusal could be entertained on the allegations made against the Court, the Registry, and persons connected with earlier matters. (ii) Whether the applicant's conduct and pleadings warranted initiation of contempt proceedings and interim restraints pending consideration of the contempt action.

Issue (i): Whether the applicant's plea for recusal could be entertained on the allegations made against the Court, the Registry, and persons connected with earlier matters.

Analysis: A recusal request must be justified on a real conflict of interest or personal disqualification, and not on unfounded assertions made after adverse orders. The allegations were directed against the sitting Judge in his official capacity and against the Registry on the basis of official acts in earlier proceedings. The Court also noted that a similar matter concerning the Registry had earlier been heard without objection, and that the plea of recusal was raised only after the applicant was required to take responsibility for serious allegations by affidavit. In these circumstances, no ground for recusal was made out.

Conclusion: The plea for recusal was rejected.

Issue (ii): Whether the applicant's conduct and pleadings warranted initiation of contempt proceedings and interim restraints pending consideration of the contempt action.

Analysis: The pleadings and repeated publications were found to contain wild, reckless and scurrilous allegations against Judges, officers of the Court, the Government Pleader and the Registry, coupled with attempts to browbeat the Court and to obtain favourable orders through false and vexatious proceedings. The Court treated this as an abuse of the process of Court and as conduct attracting the law of contempt. In the exercise of its power to protect the purity of judicial proceedings, the Court decided to frame draft charges, issue notice, place the matter before the Chief Justice for constitution of the proper Bench, and impose interim restraints against further litigative and media-based repetition of the alleged contemptuous acts.

Conclusion: Contempt action was initiated and interim protective directions were issued against the applicant.

Final Conclusion: The Court refused to accede to the applicant's attempt to shift the matter away from the assigned Bench and instead proceeded to commence contempt proceedings on the basis of the applicant's conduct, while preserving the authority and integrity of the Court pending further adjudication.

Ratio Decidendi: A litigant, including an advocate appearing in person, cannot compel recusal on the basis of unsubstantiated allegations or use scandalous pleadings and publications to browbeat the Court; where such conduct amounts to an abuse of process and threatens the administration of justice, the Court may initiate contempt proceedings and pass protective interim orders under its constitutional power.

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