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Issues: Whether a public speech broadcast by the Chief Minister, commenting on a matter then pending before the Court and supporting the impugned order, amounted to contempt of court by being calculated to interfere with the due administration of justice.
Analysis: A publication or speech may amount to contempt if it is calculated to interfere with the course of justice, prejudice parties to pending proceedings, or create an atmosphere likely to deter persons from pursuing similar claims. The absence of direct reference to the pending petition or of proof that the Judge was actually influenced is not decisive. The controlling test is whether the words, in the surrounding circumstances, were likely to obstruct or interfere with justice. The speech here presented the Government's defence before the dispute was tried, characterised the affected traders in a prejudicial manner, and was likely to affect both the petitioners and others with similar claims. The fact that the matter was heard by a Judge without a jury did not take the conduct outside contempt jurisdiction.
Conclusion: The speech amounted to contempt of court, though treated as a technical contempt warranting only disapproval and no substantive punishment.
Final Conclusion: The appeal failed, and the order recording disapproval of the Chief Minister's conduct was left undisturbed.
Ratio Decidendi: Any public comment on a pending proceeding that is calculated to prejudice parties, deter litigation, or interfere with the due administration of justice constitutes contempt, even if the maker did not intend such interference and even where the case is tried by a judge without a jury.