Criminal contempt procedure must be strictly followed; failure to frame charges and supply material vitiates conviction.

Criminal contempt proceedings are quasi-criminal and require strict compliance with mandatory procedure and natural justice. The alleged contemnor must be informed of the precise charge, supplied with the material relied upon, and given a fair opportunity to defend. Where the applicable rules require the charge to be reduced into writing and served with supporting documents, those safeguards are mandatory. An incomplete or misleading notice, coupled with failure to frame proper charges and furnish the relied-upon material, causes serious procedural prejudice and vitiates the conviction; the contempt conviction was therefore unsustainable and the appeals succeeded.

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Issues: Whether the contempt conviction could be sustained when the alleged contemnors were not informed of the specific charges, the supporting material was not furnished, and the mandatory procedure under the applicable High Court rules was not followed.

Analysis: Proceedings for criminal contempt are quasi-criminal in nature and require strict adherence to the prescribed procedure and to the principles of natural justice. The alleged contemnor must know the precise charge, must be furnished the material on which the charge is founded, and must be given a fair opportunity to defend. Where the rules framed under the Contempt of Courts Act require charges to be reduced into writing and served with the relevant documents, those requirements are mandatory. A conviction based on an incomplete and misleading notice, without framing proper charges and without supplying the material relied upon, results in serious procedural prejudice and vitiates the proceeding.

Conclusion: The contempt conviction was unsustainable and liable to be set aside.

Final Conclusion: The appeals succeeded because the contempt proceedings were conducted in breach of mandatory procedural safeguards and the appellants were deprived of a fair opportunity to meet the accusation.

Ratio Decidendi: In criminal contempt proceedings, non-compliance with mandatory procedural rules and denial of a fair opportunity to meet the specific charge vitiate the conviction.

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