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Contempt of Court | Case Reference

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Contempt of Court

Contemnor undermined the authority, dignity, prestige and sanctity of the very prestigious seat of justice defying his Lordship's order. It difficult to accept the apology of the contemnor. Contemnor found guilty for the offence of contempt of Court. This kind of arrogant behaviour on the part of a subordinate judicial officer should not be taken leniently. Since the contemnor has already retired from service and is enjoying his retired life, we have taken lenient view to impose a small sentence after convicting him for contempt. [73 DLR 157]

Contempt of Court

Whether a learned Counsel may bring any matter to the notice of the Court that may, in his view, call for an action under the Contempt of Court Act.

Whether an Advocate has every right to represent his client and protect his interests by filing an appeal before the appellate forum.

(i) A learned Counsel may bring any matter to the notice of the Court that may, in his view, call for an action under the Con- tempt of Court Act.

(ii) An Advocate has every right to represent his client and protect his interests by filing an appeal before the appellate forum, but he cannot, while the appeal is pending, ascribing somethings, by publishing a news report in his capacity as a Court reporter, which is not in the judgment. M. SaleemUllah Vs. The State 13BLD (AD)3

Ref: 15 DLR(SC) 355, AIR 1936 (P.C) 141 at pages 145-146; 28DLR(HCD)285; St. James Evening Post Case,(1742) 2ATK649; (1895)11 TIR 1976; (1922) Ich. 276; (1900) 2QB 36(at pp 40); (1899) AC 549(4); 2 EHRR 245 Cited

 

Contempt of Court

By making absurd comments, uninformed criticism and vituperative innuendoes on the judgments of the Appellate Division, the learned Judges of the High Court Division have placed themselves well within the perimeter of Contempt of Court Act (XII of 1926)

Md. Sher Ali and others Vs. The State and another) 14BLD(AD) 84 Ref: 35 DLR. (AD) 147; 45 DLR(AD) 9 and 175; A.I.R. 1945 (PC) 18.

 

Contempt of Court

The power of the High Court Division to institute a contempt proceeding is a special one. It is competent to deal with the matter summarily and to adopt its own procedure. Contempt of Court Act (XII of 1926) Ss. 2&3 Badsha Mia and others Vs. Abdul Latif Majumder and others, 14BLD(AD) 237 Ref: A. I. R. 1954 (SC) 186-Cited

 

Contempt of Court

A statement which neither directly nor indirectly imputes any aspersion to a Judge and the Court nor does it contain any scandalous statement against a Judge or the Judiciary to lower down its image in the estimation of the general public but serves as a constructive criticism relating to the mode of appointment of the Judges of the Supreme Court does not constitute contempt of Court. It is more so, when the disputed statement makes no reference to the judgment of any Judge of either Division of the Supreme Court or of any Judge subordinate thereto- Contempt of Courts Act, 1926 (XII of 1926) Section.3

Dr. Ahmed Husain Vs. Shamsul Hug Chowdhury, 16BLD(HCD)116

 

Contempt of Court

A bonafide and honest criticism of a judicial exercise is permissible only when it is aimed at improving its quality by way of healthy and constructive criticism. But when a writing is couched in scandalous and offensive language and it brings the Court into disrespect and disrepute in the eye of the general public and castigates its dignity and majesty, the writer concerned does commit contempt of the Court-Contempt of Courts Act, 1926 Section.3

The Judges of the High Court Division Vs. Ashok Kumar Karmaker and others, 16BLD(HCD)233

 

Contempt of Court

Arms of the High Court Division are long enough to catch and punish any delinquent how high soever-Contempt of Court Act, 1926 (XII of 1926) Sections-2 and 3

Almas Ali Vs. Sohrab Miah and others, 17BLD (HCD) 150

 

Contempt of Court

The issuance of the Rule for contempt of Court, appearance of the opposite party be- fore the Court in person as per direction of the Court, expression of sorrow and remorse before the Court by the opposite party together with his past sufferings and the de- tailed description of prevailing circumstances and the recent happenings are sufficient grounds to take a lenient view towards him in the instant case. It is expected that journalists should be very vigilant, alert and careful in the future in publishing Court proceedings and news and in making comments with regard to the judiciary-Contempt Court Act. 1926; Sections.2 and 3

The State Vs. ShafiqueRehman, 17BLD (HCD) 278

 

Contempt of Court

Refusal to give a hearing to a contemner is the judicial discretion of the Court. But this discretion has to be exercised sparingly. The Court may, however, refuse to hear a contemner for gross violation of the Court's order impeding the course of justice. Sections-2 and 3

Quasem Cotton Mills Ltd. Vs. Bangla- deshShilpaRinSangstha, 17BLD (HCD) 625

Ref: 1868 L.R. Vol.IV Court of Exche- quer, 13; 46DLR617; 82 I.C. 292 and (1990)2 All. E.R. 1; (1952) 2 All E.R. 567 at page 574 Cited

 

Contempt of Court

The jurisdiction of contempt must be taken with utmost care so that it is not used on occasions or in cases to which it is not ap- propriate. In the instant case, the learned Judges of the High Court Division took a too drastic step for punishing the appellant for contempt of court, being a little touchy and unduly sensative, which was not at all called for-Contempt Court Act, 1926; Sections.2 and 3.

S.A.M. Iqbal Vs. The State and another, 18BLD (AD) 195

Ref: A.IR. 1958 (Calcutta) 474; 14DLR (SC)273; 15 DLR(SC)150-Cited

 

Contempt of Court

In both the news items it has not been stated that the borrower would be able to pay on the basis of earlier re-schedulement of the loan and a picture was deliberately depicted as if this Court stood in the way of the bor- rower's repayment of the loan. It appears in both the news items this Court has been maligned and scandalized to lower it in the estimatation of the members of the public. In both the news items name of the reporter has not been published. Therefore the Rule was issued only on the editors and publisher and printer. The High Court Division can very much realies that the contemners have been used as persons by some unseen hands to make the borrower a hero at the cost of honour and prestige of this Court.

It is grossest type of contempt to malign and scandalize the highest Court and its Judges by publishing untrue and twisted news and comment in the newspaper. The High Court Division held that the contemners guilty of committing contempt of this Court. Since the contemners have tendered unqualified apology and have thrown themselves to the mercy of this Court considering that they are not the authors of the contemptuous writing, this court decided to accept their apology subject to the direction-Contempt Court Act, 1926; Sections-2 and 3

Shahidul Islam Vs. MahbubulAlam&ors., 19BLD (HCD) 601


আদালত অবমাননা আইনের অধীনে ব্যবস্থা গ্রহণের কোনও ভিত্তি না পেলে দায়রা জজ বা অন্য কোনও বিচারিক কর্মকর্তা এসব আবেদন এই আদালতে প্ররণের জন্য কেবল পোস্ট বাক্স হিসেবে কাজ করবেন না। আনোয়ারুল হক বনাম গোলাম মাহমুদ মোঃ মহসিন, ৫১ ডিএলআর (১৯৯৯) ২৪২


Contempt of Court Act (XI of 1926)
Ss. 2 and 3-The contemnors have to be given a specific decision in respect of fixing seniority of the non-cadre family planning officers appointed after 1985 at the time of their encadrement in keeping with the Seniority Rules, 1983. In doing so if the government comes to a wrong decision by interpretation of Seniority Rules, 1983 in its own way, there will be no contempt of Court as this Division in the judgment did not give specific direction upon the government as to which Rules (i.e. Rule 3(e) or 4) of BCS Seniority Rules, 1983 shall have to he followed in determining seniority of the said noncadre officers appointed after 1985 and in that score if anyone is aggrieved by the decision of the government may take recourse of law in an appropriate forum, if so advised. Amanullah (Md.) Vs. Abdul Aziz (Spl Original), 65 DLR (2013)-HCD-485.


Contempt of Courts Act, 1926


Section 2(3) This section provides for certain cases of contempt of lawful authority of a court of justice committed in presence of the court. It is a direct contempt of court and empowers all courts including a court of Magistrate or an Assistant Judge to punish an offender be he a lawyer or anyone else summarily in respect of the offences mentioned therein. The subordinate courts can sufficiently vindicate their dignity by proceeding against the offenders under this provision, Legislature has deemed it proper to exclude such cases from the jurisdiction of the High Court Division under section 2(3) of the Contempt of Courts Act, 1926. Bangladesh -VS- Naznin Begum (Most) (3 LM (AD) 66] 


Facebook Status- We believe that the contemnor will not commit such an offence again. However, he admits the fact that he has committed the offence and thus the damage of bringing the Court and the administration of justice to disrepute has been done. The two items published by the contemnor in the social media, namely Facebook are a direct affront to the constitutional authority of the Honourable Chief Justice and the Supreme Court and had the effect of lowering the dignity of the position of the Honourable Chief Justice and the Supreme Court. Evidently the contemnor achieved his intended goal as can be seen by the posts of his followers who apparently supported his views and applauded his comments.


At the time of issuing notice upon the contemnor on 12.08.2020 he was directed not to appear before any Bench of the Supreme Court from that date until his appearance in court on 20.08.20. He has thus suffered the inability to exercise his privilege of appearing before the Supreme Court for nine days


We find that the contemnor has admitted his guilt. However, in view of his apology and assurance that he will never commit such offence again, and the fact that he has refrained from appearing before any Bench of the Supreme Court as ordered by this Court, we are not inclined to take the matter any further. This contempt proceeding is disposed of. Government of Bangladesh -VS- Syed Mamun Mahbub, (9 LM (AD) 674]


Contempt-  The contemners stated that they have already withdrawn the letter of cancellation of lease and intimated the lessee (petitioner) to get back the impugned 'Ghat' for collection of toll under the lease agreement. The contemners have already complied with the order passed by this Court, we are inclined to accept their unconditional apology as the same has been filed at the earliest opportunity. Accordingly, this contempt petition is disposed of and the contemners are exonerated from the charge of contempt. Alamgir Hossain (Afd.) VS Mohammad Mubarak Hossain. 17 LM (AD) 246]


General Principles of Legal Ethics, the moral responsibilities of a Counsel


(a) In theory it is the King or Sovereign who presides in the Court of justice and the Judge is merely the mouthpiece and representative of the Sovereign. Respect shown to the Court is, therefore, respect shown to the Sovereign representative the Judge is. whose


(b) An advocate is like the Judge, himself, an officer of the Court and an integral part of the judicial machine. The legal profession consists of the Bar as well as the Bench and both have common aims and ideals.


(c) Not only litigants and witnesses but the general public will get their inspirations from the example of advocates. It is necessary for the administration of justice that Judges should have esteem of the people. If judges are not respected it tends to impair public confidence in the administration of justice.


(d) It is the good manners and advocates before anything else are "gentlemen of the Bar."


(e) Even from a purely practical standpoint, there is nothing to be gained but there is much to lose by antagonizing the Court. Conflict with the Judge renders the trial disagreeable to all and has generally an injurious effect upon the interests of the client.


(f) The usual practice in modern times is to appoint Judges from among the members of the Bar and even where this rule is not strictly observed the Bench is fairly representative of the Bar.


(g) It is necessary for dignified and honourable administration of justice that the Court should be regarded with respect by the suitors and people. (Para- 173); The State VS Mr. Swadesh Roy. [2 LM (AD) 582]



Contempt of Court Act, 1926


Contempt of Court- We have given our anxious thoughts to the fact that the contemnor has tendered his so-called "unconditional apology" and has suffered eight days in jail. However, we have also to consider that the High Court Division was not satisfied that the apology offered by the contemnor was sufficient to exonerate him completely. We are not in a position to change that view since it is the High Court Division which, found that the contemnor was in contempt of Court...S.O.M Kalimullah =VS= Oxinel Services Pte. Ltd., [10 LM (AD) 432]


Contempt of Court- Sentenced to confinement All elements of grave contempt of court are present in the impugned article. Mr. Swadesh Roy, the writer and Mr. Atiqullah Khan Masud (M.A.Khan Masud), editor, printer and publisher of the Daily Janakantha are found guilty of contempt. The contempt proceeding succeeds. Contemnors Mr. Swadesh Roy (author) and Mr. Mohammad Atiqullah Khan Masud (M.A. Khan Masud) are sentenced to confinement till rising of this Court, this day and to pay a fine of Tk.10,000/- (Ten thousand) each to be contributed to two charitable organizations within one week from date, failing which, they shall suffer seven days simple imprisonment. (Para- 8); The State VS Mr. Swadesh Roy. (2 LM (AD) 576]


Criminal contempt and a violation of the provisions of the Constitution- The respondents have intentionally made the utterances as reported and have indeed expressly admitted their guilt. They have acted in violation of law and are in breach of their oath of office to preserve, protect and defend the Constitution. In their exuberance, they have undermined the sanctity of the institution of the judiciary by questioning the justice delivery system. The Constitution enjoins all citizens to abide by the law and makes the decisions of the Supreme Court law to be given effect to by all. The respondents have scandalized the Supreme Court in a highly motivated manner in order to influence the judgement of the Court. This is gross criminal contempt and a violation of the provisions of the Constitution. The contemnors deserve no sympathy other that the lenient view taken in awarding sentence which has already been expressed in the short order passed by this Court on 27th March, 2016. The State =VS= Adv. Md. Qamrul Islam, M.P & another, [1 LM (AD) 28]

Contempt of Court-The editor of a newspaper is responsible for deciding what materials will be published. To that extent whatever is ultimately printed is according to the decision of the editor. The editor cannot escape the responsibility of scrutinizing materials published in any newspaper. If he allows publication of contemptuous reports, then he is equally liable. Ekramul Haque Balbul vs Md Faiz, 67 DLR (AD) 208

Contempt of Court-When allega- tions/imputations are brought against a Judge, a distinction must be drawn between what is personal, i.e. purely against the Judge, without any intention thereby to bring disrepute upon the Court, and what is aimed at maligning the Court and the system of delivery of justice. If it is purely against the Judge personally, it would be a matter of libel action by the Judge. Ekramul Haque Balbul vs Md Faiz, 67 DLR (AD) 208

Contempt of Court- If such an apology were to be accepted, as a Rule, and not as an exception, we would in fact be virtually issuing a 'licence' to commit contempt of court with impunity. Abhimunnyo Singha vs Shauli Shumon, 66 DLR 197

Contempt of Court-Since this is her First Offence and she has solemnly promised never to do any act of omission in defiance of or in disobedience to any order/direction of this Court or any other Court of law we have taken a view and seriously censor and warn her for her conduct and if she repeat such kind of act in future she will be severely dealt with. (PER MD ASHRAFUL KAMAL, J) Abhimunnyo Singha vs Shauli Shumon, 66 DLR 197

Contempt of Court-If an impression is created in the minds of the public that the Judges in the highest Court act on extraneous considerations, the confidence of the whole community in the administration of justice is bound to be undermined and no greater mischief than that can be imagined. State vs Swadesh Roy, "Daily Janakantha", 68 DLR (AD) 162

Contempt Matter

Applications for drawing up proceedings of contempt of Court against Sheikh Hasina, the Prime Minister of Bangladesh are disposed of with a note of desire that the Hon'ble Prime Minister shall be more careful and respectful in making any statement or comment with regard to the Judiciary or the judges or the Courts of Bangladesh in future Md Mozammal Hoque J: Mainul Hosein vs Sheikh Hasina Wazed 53 DLR 138.

Per Md Abdur Rashid J (agreeing): In practice, this Division has been following the same path charted by the Appellate Division for taking cognizance of an offence of contempt. Mainul Hosein & others vs Sheikh Hasina Wazed 53 DLR 138.

Per Md Abdur Rashid J (agreeing): Juris diction This Division may suo moto or on the information received take cognizance of an offence of contempt. The jurisdiction is sui generis and consists of a special set of principles as stated in AIR 1954 (SC) 186 and PLD 1972 (SC) 39. Mainul Hosein vs Sheikh Hasina Wazed 53 DLR 138.

Per Md Abdur Rashid J (agreeing): A con- tempt proceeding is quasi-criminal in nature. The contemner is entitled to benefit of doubt, and since the Court is both prosecutor and judge, rule as to proof of guilt of the contemner must be strictly observed. Mainul Hosein vs Sheikh Hasina Wazed 53 DLR 138.

Per Md Abdur Rashid J (agreeing): What could readily be read as contemptuous in 1900 or 1912 or 1936 is not so easily read now in the context of expanding rights guaranteed as funda- mental to human existence under the Constitution. Mainul Hosein vs Sheikh Hasina Wazed 53 DLR 138.

Per Md Abdur Rashid (agreeing): State ments based on inaccurate assessments of situation, however grossly misreading those may be, cannot amount to contempt of court. More over, in the absence of mens rea, no contempt is established. Mainul Hosein vs Sheikh Hasina Wazed 53 DLR 138.

Per Md Abdur Rashid J (agreeing): It is not correct to think that the judges are above law or there is no accountability of the judges under the Constitution. The sooner it is understood the better for the whole nation. Mainul Hosein vs Sheikh Hasina Wazed 53 DLR 138.

Per Md Abdur Rashid J (agreeing): The Prime Minister of the Republic is the leader of the House of the Nation. The Parliament comprises of members, both of the ruling party as well as of the Opposition. The aggrieved members of the Parliament could have more opportunities and better scope to hold their leader to account in the Parliament for her statements. But they preferred to abdicate their constitutional privilege and sub- mitted before the Court to punish their leader by this Division for infraction of the Constitution. Such novel step, unprecedented in the constitu- tional history, I am afraid, would not create any good precedent. Mainul Hosein vs Sheikh Hasina Wazed 53 DLR 138.

Per Md Abdur Rashid J (agreeing): The people are equally and strongly divided like the lawyers. Such division demands serious cir- cumspection from the judiciary. Then the reason for such division is nowhere found except in the politics. The judiciary must guard against all chances of the party politics creeping into the holy precincts of the citadel of justice lest it ultimately fell victim to politics. Mainul Hosein vs Sheikh Hasina Wazed 53 DLR 138.


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