Contempt limitation as a jurisdictional bar: proceedings must begin within one year, and delay cannot be condoned under the Limitation Act.

Section 20 of the Contempt of Courts Act, 1971 was treated as a jurisdictional bar, requiring contempt proceedings to be initiated by the court within one year of the alleged contempt; stale contempt could not be acted on after that period. The Limitation Act, 1963 could not be invoked through Section 29(2) read with Section 5 to condone delay, because contempt is not initiated by a party in the ordinary sense and the court cannot condone its own delay. The court could also notice the limitation bar on its own motion, even without a specific plea.

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Issues: (i) Whether proceedings for contempt could be initiated after the expiry of one year from the date of the alleged contempt under Section 20 of the Contempt of Courts Act, 1971. (ii) Whether delay in initiating contempt proceedings could be condoned by invoking Section 29(2) read with Section 5 of the Limitation Act, 1963.

Issue (i): Whether proceedings for contempt could be initiated after the expiry of one year from the date of the alleged contempt under Section 20 of the Contempt of Courts Act, 1971.

Analysis: Section 20 was treated as a jurisdictional bar and not merely as an ordinary period of limitation. In contempt matters, the person bringing the alleged contempt to the notice of the court is only a relator or informant, and the court alone initiates the proceeding. The relevant date for Section 20 is the date of the alleged contempt, and the court must apply its mind and initiate proceedings within one year. The Act was also treated as a complete code on this aspect, excluding stale contempt from further action.

Conclusion: Proceedings could not be initiated after the expiry of one year from the alleged act of contempt, and the court's jurisdiction was barred.

Issue (ii): Whether delay in initiating contempt proceedings could be condoned by invoking Section 29(2) read with Section 5 of the Limitation Act, 1963.

Analysis: Section 29(2) applies only where the special law is inherently of a kind to which the Limitation Act provisions can attach. Contempt proceedings do not involve a petition or application in the ordinary sense, and there is no party entitled to institute proceedings in the manner contemplated by Section 5. Since the court itself initiates the proceeding and cannot condone its own delay, Section 5 was held inapplicable.

Conclusion: Delay could not be condoned under Section 29(2) or Section 5 of the Limitation Act, 1963.

Issue (iii): Whether the bar of limitation under Section 20 could be noticed by the court even if not specifically pleaded by the respondents.

Analysis: The one-year bar was treated as going to the court's jurisdiction and as a condition precedent to taking action. For that reason, the court was bound to examine the bar on its own, irrespective of pleadings.

Conclusion: The court could take notice of the limitation bar on its own motion.

Final Conclusion: The contempt petition was barred by Section 20 because no proceeding had been initiated within one year of the alleged contempt, and the petition failed on jurisdictional grounds.

Ratio Decidendi: Section 20 of the Contempt of Courts Act, 1971 imposes an absolute jurisdictional bar requiring initiation of contempt proceedings within one year of the alleged contempt, and the Limitation Act cannot be used to condone delay in such proceedings.

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