Mehmood Pracha vs Central Administrative Tribunal

Criminal Appeal · 2022 INSC 813Decided 10 Aug 2022
Criminal Appeal No. 892 of 2020
K.M. Joseph · Hrishikesh Roy

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.

Contempt of CourtDelhi High Court

Mansi Brar vs. Mohit Singh

The Court found that the subject properties had already been sold before the status quo order was passed. The respondent did not disclose this in his reply and instead relied on other grounds, and the exact position emerged only after the Court directed him to file an affidavit. The Court held that the earlier order was passed on the basis of this non-disclosure, and that he had also wilfully breached his undertaking. He was held guilty of civil contempt under Section 2(b) of the Contempt of Courts Act, 1971. The text of the judgment supplied does not show a sentence or penalty.

Decided 1 Oct 2026Read case
Contempt of CourtDelhi High Court

Dr. Naresh Kumar vs. Shri Ajay Kumar Bhalla & Ors.

The Court found the respondents had in fact complied with the specific direction in the earlier order: the petitioner had been promoted to CMO (OG) as ordered, and had even been further promoted to CMO (SG) since then. Since the scope of contempt proceedings is confined to the exact directions given in the order allegedly violated, and the order never addressed promotion to DIG, the Court held the petitioner could not use contempt proceedings to expand relief to a promotion issue never covered by the original order, and dismissed the petition.

Decided 24 Sept 2026Read case
Contempt of CourtDelhi High Court

Bharat Singh Rawat vs. Dr. Poonam Singh Rawat

Relying on Supreme Court precedent (Midnapore Peoples' Coop. Bank Ltd. v. Chunilal Nanda), the Division Bench held that an appeal under Section 19 of the Contempt of Courts Act is maintainable only against an order actually punishing someone for contempt, not against an order merely directing compliance. Since no punishment had been imposed, the impugned order was not appealable under Section 19, and the appeal was disposed of, with liberty given to the appellant to separately seek clubbing of the multiple pending cases before the single judge.

Decided 22 Sept 2026Read case
Contempt of CourtDelhi High Court

Naima Khatoon vs. Utpal Chakraborty & Anr.

The Court found that two specific cheques relied upon had never actually been presented for encashment, so no contempt arose from them. However, a receipt dated 30.11.2017 for Rs. 1,00,320 remained unclear as to whether that amount was actually collected. The Court did not impose a contempt penalty but directed that if the amount had indeed been realized by the respondents in violation of the earlier orders, it must be refunded to the petitioner with 12% annual interest within eight weeks.

Decided 21 Sept 2026Read case
Contempt of CourtDelhi High Court

Government of NCT of Delhi vs. Ram Niwas

The High Court declined to interfere, holding it saw no basis to exercise its certiorari jurisdiction over what were essentially procedural orders granting further time and recording the government's own officers' assurances of compliance: assurances given while the government was represented by two counsel, not under any unfair coercion. The Court clarified its order was not an opinion on the merits of the underlying contempt petition, which the Tribunal remains free to decide.

Decided 21 Sept 2026Read case
Contempt of CourtDelhi High Court

Teena Kapoor vs. Municipal Corporation of Delhi and Ors.

The Division Bench found that although the appellant knew of the pending litigation when she bought the flat and chose not to join those proceedings, she still faced the imminent threat of demolition without having been heard. The Court therefore directed that no demolition take place until her impleadment applications are decided by the Single Judge, permitted her to also seek impleadment in the related civil suit, and recorded her undertaking not to carry out any further construction in the meantime.

Decided 18 Sept 2026Read case