Contempt for evading surrender through prolonged hospital admission and for aiding obstruction of justice

Wilful disobedience of a surrender direction, coupled with prolonged hospital admission without meaningful medical justification, was treated as obstruction of the administration of justice and civil and criminal contempt. The record referred to 527 days of admission, repeated non-compliance with warrants, and conduct inconsistent with genuine indoor treatment. Medical professionals were also found to have aided the evasion by extending admission and providing cover for continued avoidance of arrest and court process. The judgment records contempt findings against both the respondent and the concerned professionals and defers sentence for further hearing.

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Issues: (i) Whether the respondent was guilty of contempt for wilfully disobeying the direction to surrender and for obstructing the administration of justice by remaining admitted in hospital without medical justification; (ii) Whether the medical professionals were liable for contempt for extending prolonged hospital admission and thereby assisting the respondent in evading arrest and defeating the court's orders.

Issue (i): Whether the respondent was guilty of contempt for wilfully disobeying the direction to surrender and for obstructing the administration of justice by remaining admitted in hospital without medical justification.

Analysis: The direction cancelling bail and requiring surrender was binding on the respondent. The record showed prolonged hospital admission for 527 days, absence of meaningful medical justification, no laboratory tests for long periods, repeated non-compliance with warrants, and conduct inconsistent with any genuine need for continued indoor treatment. The prolonged admission was found to have been used to defeat the court's direction and the trial court's coercive process.

Conclusion: The respondent was held guilty of civil contempt and criminal contempt for wilful disobedience and obstruction of justice.

Issue (ii): Whether the medical professionals were liable for contempt for extending prolonged hospital admission and thereby assisting the respondent in evading arrest and defeating the court's orders.

Analysis: The hospital record and the enquiry report showed that the respondent was repeatedly declared fit to be produced in court, yet remained admitted until a court-directed inquiry exposed the circumstances. The explanation that the respondent merely exploited the hospital for financial advantage was rejected. The conduct of the hospital and its medical professionals was found to have provided cover and protection to the respondent and to have assisted in frustrating the court's orders.

Conclusion: The medical professionals were held guilty of contempt for aiding the respondent and obstructing the administration of justice.

Final Conclusion: The judgment records findings of contempt against the respondent and the concerned medical professionals, while deferring punishment and directing their further appearance for hearing on the question of sentence.

Ratio Decidendi: A person not bound by the underlying order may still commit contempt if, with knowledge of the circumstances, he knowingly assists in frustrating the court's process and thereby obstructs the administration of justice.

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