Criminal contempt for repeated unsubstantiated allegations against counsel and disruption of court proceedings led to imprisonment and fine.

Repeated, unqualified allegations against counsel assisting the Court, coupled with refusal to withdraw them unconditionally and continued disruptive communications, were treated as criminal contempt because the conduct was found to deliberately interfere with judicial proceedings and undermine advocates performing their professional duties. The Court found no bona fide truth-based justification for the accusations, noted that repeated opportunities to apologise or retract were not effectively used, and held the respondent guilty of criminal contempt. The respondent was sentenced to simple imprisonment for one week and a fine.

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Issues: Whether the respondent's repeated allegations against counsel assisting the Court, his refusal to withdraw them unconditionally, and his persistent disruptive conduct constituted criminal contempt punishable under the Contempt of Courts Act, 1971, and what consequence should follow.

Analysis: The respondent had earlier filed an intervention application which was rejected, but thereafter continued sending emails, affidavits and communications levelling serious allegations against the Revenue's counsel and other participants in the proceedings. He repeatedly stated that he would withdraw some allegations only conditionally, while reserving the right to press them elsewhere, and did not establish any bona fide justification on the basis of truth. The conduct was found to be a deliberate attempt to prejudice and interfere with the due course of judicial proceedings and to deter advocates assisting the Court in the discharge of their professional duties. The Court held that such behaviour amounted to criminal contempt and that the repeated opportunities given to the respondent, including the opportunity to tender an unconditional apology, had not been effectively availed of.

Conclusion: The respondent was found guilty of criminal contempt of court and was sentenced to simple imprisonment for one week and a fine of Rs. 2,000/-.

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