Gross contempt by advocates for disrupting court proceedings; belated apology was insufficient, with sentence deferred.

Advocates who deliberately stormed courtrooms, disrupted proceedings and scandalised the authority of the Delhi High Court were found guilty of gross contempt because their conduct interfered with the administration of justice and undermined court discipline. A belated apology was treated as insufficient to show genuine contrition, so it did not secure complete exoneration. The Court, however, deferred immediate sentencing for one year and warned that any further misconduct would attract punishment.

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Issues: (i) Whether the contemners, being advocates who stormed courtrooms, disrupted judicial proceedings and scandalised the authority of the High Court, were guilty of contempt of court; (ii) Whether the apology tendered by the contemners was bona fide and fit to be accepted, and what consequential order should follow.

Issue (i): Whether the contemners, being advocates who stormed courtrooms, disrupted judicial proceedings and scandalised the authority of the High Court, were guilty of contempt of court.

Analysis: The conduct attributed to the contemners was not a spontaneous protest but a coordinated and deliberate intrusion into functioning courtrooms. The acts interfered directly with the administration of justice, intimidated court users and officers, and tended to lower the authority of the Court. As advocates, they were under a heightened duty to uphold decorum, discipline and the rule of law rather than obstruct judicial work.

Conclusion: The contemners were held guilty of gross contempt of court.

Issue (ii): Whether the apology tendered by the contemners was bona fide and fit to be accepted, and what consequential order should follow.

Analysis: The apology was not tendered at the earliest opportunity and emerged only after the proceedings had progressed and the Court had indicated its serious view of the matter. The surrounding circumstances showed defiance rather than genuine contrition, and the apology was treated as insufficient to erase the gravity of the misconduct. At the same time, the majority considered the totality of circumstances, including the apology and the need to watch future conduct, and chose not to impose immediate imprisonment and fine.

Conclusion: The apology was not accepted as sufficient for complete exoneration, but the sentence was deferred for one year and the contemners were warned that any ation would attract punishment.

Final Conclusion: The proceedings culminated in a finding of gross contempt against the contemners, with immediate sentence withheld and deferred subject to their future good conduct.

Ratio Decidendi: Advocates who deliberately obstruct court functioning and scandalise the authority of the court commit gross contempt, and a belated apology that is not shown to be genuine does not automatically entitle them to discharge or immunity from punishment.

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