Criminal contempt threshold not met where party deletion request and case conduct did not scandalise or obstruct justice.

A request to delete a party from the array of parties does not amount to a waiver of the right to be heard, as it only asserts that the party is not necessary or proper. Allegations of suppression, manipulation, and inconsistent conduct in proceedings before the Court and the Company Law Board were tested against Section 2(c) of the Contempt of Courts Act, 1971, but the record did not show any act scandalising the court, interfering with judicial proceedings, or obstructing the administration of justice. No criminal contempt was made out, and initiation of contempt proceedings was rejected.

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Issues: Whether the respondent's conduct in seeking deletion from the array of parties, appearing in the appeal, and pursuing proceedings before the Company Law Board amounted to criminal contempt under Section 2(c) of the Contempt of Courts Act, 1971.

Analysis: The allegations of suppression, manipulation, and inconsistency in appearing before the Court and the Company Law Board were examined against the statutory definition of criminal contempt. A request to be deleted from the array of parties does not mean that the applicant has elected not to be heard; it only asserts that the party is not necessary or proper. Likewise, a party's conduct in relation to oral assertions about what transpired in court cannot override the judicial record, which must be taken as conclusive unless corrected through an appropriate review or clarificatory application. The record did not substantiate any act scandalising the court, interfering with judicial proceedings, or obstructing the administration of justice.

Conclusion: No criminal contempt was made out and the application for initiation of contempt proceedings was rejected.

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