Ram Niranjan Roy v. State of Bihar
Background
A police officer intervened in public-interest proceedings about police administration but demanded attention to his own posting dispute. The High Court punished his repeated shouting and defiance with twenty-four hours' custody; in his Supreme Court appeal, he supplied an altered copy of that order and made unsupported sworn assertions about a bail application.
Decision Breakdown
The Court upheld the High Court's contempt punishment, finding that the officer's conduct openly disrupted and demeaned its proceedings. Immediate action was justified by the gross contempt committed in court and his continued lack of remorse. It separately found contempt in the Supreme Court through the altered order and false affidavit, rejecting the claimed typing error. It imposed a Rs. 25,000 fine payable to the Supreme Court Legal Services Committee within four weeks, with seven days' simple imprisonment on default.
Lesson Learnt
Arguing a personal grievance in court does not permit disruption, and filing an altered judicial order or a knowingly false affidavit can bring separate contempt consequences.