Strict proof of wilful disobedience and admissible evidence was required, so contempt allegations failed against all respondents.

Civil contempt requires clear proof of wilful disobedience of a definite and binding order, and that threshold was not met because the restraint order was directed at political parties, not specifically at the official respondents, and the record did not show deliberate defiance. Criminal contempt requires legally admissible proof beyond reasonable doubt of the actual scandalising words, and that threshold was also not met because the claim rested on newspaper reports and an edited telecast without reliable primary evidence of the full speech. The contempt allegations therefore failed against all respondents and the petitions were dismissed.

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Issues: (i) Whether respondent Nos. 1 to 5 were liable for civil contempt for wilful disobedience of the restraint order dated 30.09.2007; (ii) Whether respondent No. 6 was liable for criminal contempt on the basis of the alleged speech said to scandalise the Court and interfere with the administration of justice.

Issue (i): Whether respondent Nos. 1 to 5 were liable for civil contempt for wilful disobedience of the restraint order dated 30.09.2007.

Analysis: Civil contempt under Section 2(b) of the Contempt of Courts Act, 1971 requires clear proof of wilful disobedience. The restraint order was directed against the political parties and did not specifically command respondent Nos. 1 to 5 to act in any particular manner. The record showed that the official respondents issued instructions for maintaining law and order, protecting essential services, and facilitating transport as far as possible. The evidence did not establish beyond reasonable doubt that respondent Nos. 1 to 5 deliberately defied the Court's order or engineered any violation.

Conclusion: Respondent Nos. 1 to 5 were not guilty of civil contempt.

Issue (ii): Whether respondent No. 6 was liable for criminal contempt on the basis of the alleged speech said to scandalise the Court and interfere with the administration of justice.

Analysis: Criminal contempt under Section 2(c) of the Contempt of Courts Act, 1971 had to be proved by legally admissible material. The petitioners relied on newspaper reports and an edited telecast, but the original and reliable primary evidence of the full speech was not produced. In the absence of satisfactory proof of the actual words used, the alleged scandalising remarks could not be established beyond reasonable doubt.

Conclusion: Respondent No. 6 was not guilty of criminal contempt.

Final Conclusion: The contempt allegations were not proved against any respondent, and the contempt petitions were dismissed.

Ratio Decidendi: A finding of contempt requires strict proof: civil contempt demands wilful disobedience of a clear and binding order, while criminal contempt must be established by legally admissible evidence beyond reasonable doubt.

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