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INDIAN POLITY
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however, confined to cases where the offences are coincident or practically so.85.
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The Supreme Court issued specific guidelines regarding the interpretation of general law
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and special law. See the Box below for these Guidelines.
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Supreme Court Guidelines on Interpretation of General law and Special law
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(i) When a provision of law regulates a particular subject and a subsequent law
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contains a provision regulating the same subject, there is no presumption that
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the later law repeals the earlier law. The rule-making authority while making the
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later rule is deemed to know the existing law on the subject. If the subsequent
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law does not repeal the earlier rule, there can be no presumption of an intention
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to repeal the earlier rule;
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(ii) When two provisions of law — one being a general law and the other being
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special law govern a matter, the court should endeavour to apply a harmonious
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construction to the said provisions. But where the intention of the rule-making
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authority is made clear either expressly or impliedly, as to which law should
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prevail, the same shall be given effect.
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(iii) If the repugnancy or inconsistency subsists in spite of an effort to read them
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harmoniously, the prior special law is not presumed to be repealed by the later
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general law. The prior special law will continue to apply and prevail in spite of
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the subsequent general law. But where a clear intention to make a rule of
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universal application by superseding the earlier special law is evident from the
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later general law, then the later general law, will prevail over the prior special law.
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(iv) Where a later special law is repugnant to or inconsistent with an earlier general
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law, the later special law will prevail over the earlier general law.
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[Maya Mathew v State of Kerala86. and P Raghava Kurup v V Ananthakumari87..]
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[s 5.1] Contempt of Court
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Contempt of Courts Act, 1971 (Act 70 of 1971) makes it clear that, Contempt of Court
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means 'Civil contempt' or 'Criminal contempt'.88. 'Civil contempt' means wilful
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disobedience to any judgment, decree, direction, order, writ or other process of a Court
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or wilful breach of an Undertaking given to a Court.89. "Criminal contempt" means the
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publication (whether by words, spoken or written, or by signs, or by visible
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representations, or otherwise) of any matter or the doing of any other act whatsoever
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which – (i) scandalises or tends to scandalise or lowers or tends to lower the authority
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of any Court; or (ii) prejudices, or interferes or tends to interfere with, the due course of
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any judicial proceeding; or (iii) interferes or tends to interfere with, or obstructs or tends
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to obstruct, the administration of justice in any other manner.90. The provisions of this
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Act shall be in addition to and not in derogation of, the provisions of any other law
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relating to contempt of Courts.91. Contempt proceeding is sui generis (of its own kind
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or class or unique). It has peculiar features which are not found in criminal
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proceedings. The respondent does not stand in the position of a person accused of an
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offence. Initiation of contempt proceedings against the respondent who is already
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accused in a criminal proceedings, does not amount to double jeopardy.92. Mens rea is
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not necessary for committing contempt of Court. The main ingredient of the offence of
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contempt of Court is the result of one's contumacious act of offending the prestige and
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dignity of the judiciary so as to lower it in the estimation of the general public. Whether
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the contemnor intended it or not is of no consequence.93.
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[s 5.2] Contempt of Supreme Court and High Courts
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Articles 129 and 215 preserve all the powers of the Supreme Court and the High Court,
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respectively, as a Court of Record which includes the power to punish the contempt of
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itself. There are no curbs on the power of the High Court to punish for contempt of
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itself except those contained in the Contempt of Courts Act, 1971.94. For the judiciary
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to carry out its obligations effectively and true to the spirit with which it is sacredly
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entrusted the task, constitutional Courts have been given the power to punish for
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contempt, but greater the power; higher the responsibility.95.
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[s 5.3] Contempt of Subordinate Courts
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Every High Court shall have and exercise the same jurisdiction, powers and authority, in
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accordance with the same procedure and practice, in respect of contempt of Courts
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subordinate to it as it has and exercises in respect of contempt of itself provided that
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no High Court shall take cognizance of a contempt alleged to have been committed in
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respect of a Court subordinate to it where such contempt is an offence punishable
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under the IPC, 1860 [section 10 Contempt of Courts Act, 1971]. The procedure
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prescribed either under the Cr PC, 1973 or under the Indian Evidence Act, 1872 is not
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attracted to the proceedings initiated under section 15 of the Contempt of Courts Act.
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The High Court can deal with such matters summarily and adopt its own procedure.
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The only caution that has to be observed by the Court in exercising this inherent power
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of summary procedure is that the procedure followed must be fair and the contemnors
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are made aware of the charges levelled against them and given a fair and reasonable
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opportunity.96.
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[s 5.4] Section 228 IPC vis-a-vis Contempt of Courts Act
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What is made publishable under section 228 IPC, 186097. is the offence of intentional
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insult to a Judge or interruption of Court proceedings but not as a contempt of Court.
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The definition of criminal contempt is wide enough to include any act by a person
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which would either scandalise the Court or tend to interfere with the administration of
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justice. It would also include any act which lowers the authority of the Court or
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prejudices or interferes with the due course of any judicial proceedings. It is not limited
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to the offering of intentional insult to the Judge or interruption of the judicial
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proceedings.98.
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1. MC Verghese v Ponnan, AIR 1970 SC 1876 [LNIND 1968 SC 339] : (1969) 1 SCC 37 [LNIND
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1968 SC 339] : 1970 Cr LJ 1651 .
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2. Mobarik Ali v State of Bombay, AIR 1957 SC 857 [LNIND 1957 SC 81] : 1957 Cr LJ 1346 (SC).
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77. Subs. by the A.O. 1950, for section 5.
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78. Ramachandrappa, (1883) 6 Mad 249; Motilal Shah, (1930) 32 Bom LR 1502 : 55 Bom 89.
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79. UOI v Anand Singh Bisht, AIR 1997 SC 361 [LNIND 1996 SC 1341] : (1996) 10 SCC 153
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[LNIND 1996 SC 1341] : 1996 Cr LJ 4435 : (1996) 1 SCC (Cr) 1198.
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80. Section 41 IPC, 1860.
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81. Section 42 IPC, 1860.
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82. Bhalchandra Ranadive, (1929) 31 Bom LR 1151 , 1178 : 54 Bom 35.
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83. Hussun Ali, (1873) 5 NWP 49.
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84. Kuloda Prosad Majumdar, (1906) 11 Cal WN 100; Bhogilal, (1931) 33 Bom LR 648 .
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85. Joti Prasad Gupta, (1931) 53 All 642 , 649; Suchit Raut v State, (1929) 9 Pat 126.
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86. Maya Mathew v State of Kerala, (2010) 4 SCC 498 [LNIND 2010 SC 190] : (2010) 3 SCR 16
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[LNIND 2010 SC 190] : AIR 2010 SC 1932 [LNIND 2010 SC 190] : 2010 (2) Scale 833 [LNIND
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2010 SC 190] .
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87. P Raghava Kurup v V Ananthakumari, (2007) 9 SCC 179 [LNIND 2007 SC 215] : 2007 (2) SCR
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1058 [LNIND 2007 SC 215] : (2007) 3 Scale 431 [LNIND 2007 SC 215] .
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88. Section 2(a).
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89. Section 2(b).
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90. Section 2(c).
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91. Section 22.
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92. Delhi Judicial Service, Association, Tis Hazari Court v State of Gujarat, AIR 1991 SC 2176
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[LNIND 1991 SC 446] : 1991 (4) SCC 406 [LNIND 1991 SC 446] .
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