Criminal contempt and abuse of process found where repeated proceedings were filed after suppressing prior adverse orders.

Repeated attempts to restrain the petitioner's suits, based on substantially the same grounds already rejected by the Delhi High Court and earlier proceedings before the same court, were treated as abuse of process when the respondents suppressed those adverse orders and obtained fresh interim relief. The court applied the settled meaning of criminal contempt under the Contempt of Courts Act, 1971, namely conduct interfering with the due course of judicial proceedings or the administration of justice, and held that concealment of material facts and repeated litigation on the same issue showed lack of bona fides. It further recognised inherent power to prevent repetition of such abuse and restrained further similar proceedings without prior leave. The respondents, except three given the benefit of doubt, were held guilty of criminal contempt.

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Issues: Whether the respondents were guilty of criminal contempt for repeatedly initiating proceedings to restrain the petitioner's suits by suppressing material facts and litigating the same question again, and whether preventive injunctive relief against further such proceedings could be granted.

Analysis: The proceedings taken by the respondents were examined in the light of the settled meaning of criminal contempt under the Contempt of Courts Act, 1971, namely, conduct that interferes with the due course of judicial proceedings or the administration of justice. The repeated applications were founded on substantially the same grounds that had already been rejected by the Delhi High Court and by this Court in earlier proceedings. The respondents suppressed those adverse orders when moving fresh applications and thereby misled the Court into issuing rules and interim orders. Such successive litigation on the same grounds, coupled with concealment of material facts, was treated as abuse of the Court's process and as conduct lacking bona fides. The Court also held that it had inherent power, preserved by section 22 of the Act, to prevent repetition of such abuse by restraining further proceedings of the same nature without leave.

Conclusion: The respondents, other than the three ladies who were given the benefit of doubt, were held guilty of criminal contempt; respondents 1 to 4 were convicted and fined, and an injunction was granted restraining the respondents from initiating further similar proceedings without prior leave of the Court.

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