Publication of statutory inquiry notification held not to be contempt where it was complete and unrelated to pending revisions.

Publication of a statutory notification issued under the Commissions of Inquiry Act, 1952, did not amount to contempt where the full notification, including the schedule of allegations, was published and the Commission's subject-matter was distinct from the pending criminal revisions. The Court reasoned that the notification was required to be published in the Official Gazette, the material supplied to the press was not selective or distorted, and the publication was not calculated to obstruct the due course of justice. Accordingly, the publication was held not to constitute contempt of Court, and relief was granted.

---

---

Issues: Whether publication of the full notification issued under Section 3 of the Commissions of Inquiry Act, 1952, during the pendency of criminal revision proceedings, amounted to contempt of Court.

Analysis: The notification appointing a Commission of Inquiry was required by statute to be published in the Official Gazette, and the schedule of allegations formed part of that notification. The material given to the press was the entire notification and not a selective or distorted extract. The subject-matter of the Commission's inquiry and the question pending in the criminal revisions were distinct and separate: the former concerned alleged misuse of official position, while the latter concerned the legality of the magistrate's order on withdrawal of prosecution. Since the publication was of a statutory notification in compliance with the Act and the matters were not identical, the publication was not calculated to obstruct the due course of justice.

Conclusion: The publication did not constitute contempt of Court, and the appellant was entitled to relief.

---