Mehmood Pracha vs Central Administrative Tribunal
Background
An advocate appearing before the Central Administrative Tribunal was accused of insisting during a hearing that proceedings be held "in camera" because he had something adverse to say about the Tribunal's Chairman, but then refusing to say it even after being invited to speak openly. The Tribunal treated this as contempt committed in its own presence, framed a formal charge against him under Section 14 of the Contempt of Courts Act, 1971, and, after he pleaded not guilty and demanded a trial, went ahead and convicted him without ever actually holding that trial or taking evidence, relying instead on a Supreme Court precedent (Leila David v. State of Maharashtra) about contempt committed directly before judges. He was let off with only a warning, but the finding of guilt and a direction to report him to the Bar Councils remained on record, and he appealed.
Decision Breakdown
The Supreme Court held that both Section 14(1)(c) of the Contempt of Courts Act and Rule 15 of the Contempt of Courts (CAT) Rules, 1992 require that where the person charged denies the allegation and insists on a trial, evidence must actually be taken before a finding of guilt can be recorded. The Court distinguished Leila David, noting that case involved an extreme, undisputed act of contempt (a shoe thrown at judges) committed directly before the Supreme Court itself, which has special constitutional powers under Articles 129 and 142 not available to a Tribunal, so it could not justify skipping a trial here, where the appellant flatly denied the charge and asked to be tried. Since the Tribunal convicted him without any evidence being led despite his express demand for trial, this amounted to a miscarriage of justice. The appeal was allowed, the conviction set aside, and the direction to report him to the Bar Council was also nullified, though the Court noted it would have upheld the conviction had actual evidence supported the charge.
Lesson Learnt
A person charged with contempt who denies the charge and demands a trial cannot lawfully be convicted without evidence being taken; procedural safeguards for a fair hearing apply strictly even in contempt proceedings, and a tribunal cannot bypass them by analogy to exceptional Supreme-Court-specific precedents.