Contempt appeal maintainability: an informant cannot appeal against refusal to initiate contempt or bypass the statutory scheme.

An informant in contempt proceedings is not, by that status alone, an aggrieved party entitled to challenge an order declining to initiate or punish contempt. The contempt jurisdiction remains primarily between the court and the alleged contemnor, so a person who merely alerts the court cannot claim an appeal under Section 19 of the Contempt of Courts Act, 1971 when no contempt is found. An intra-court appeal under Clause 15 of the Letters Patent also cannot be used to bypass that limited statutory appellate scheme. The result is that the contempt appeal was not maintainable and the finding of no contempt remained undisturbed.

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Issues: (i) Whether an informant in contempt proceedings has a right to maintain an appeal against an order refusing to initiate or punish for contempt, and whether an intra-court appeal under Clause 15 of the Letters Patent is maintainable in such a case.

Analysis: The contempt jurisdiction is primarily between the Court and the alleged contemnor. A person who merely brings alleged contempt to the notice of the Court does not become a complainant or an aggrieved party as of right. If the Contempt Court records that there is no merit in the petition and no contempt is made out, the informant cannot claim an appeal under Section 19 of the Contempt of Courts Act, 1971. The appellant cannot indirectly obtain through Clause 15 of the Letters Patent what is not available under the contempt statute itself.

Conclusion: The appeal was not maintainable and the objection raised by the Registry was correctly sustained, against the appellant.

Final Conclusion: The contempt appeal was rejected at the threshold for want of maintainability, leaving the finding of no contempt undisturbed.

Ratio Decidendi: An informant in contempt proceedings is not an aggrieved party entitled to appeal against an order declining contempt action, and an intra-court appeal cannot be used to bypass the limited appellate scheme under Section 19 of the Contempt of Courts Act, 1971.

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