Shanmugam @ Lakshminarayanan v. High Court of Madras

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Citations: 2025 INSC 619
Court: Supreme Court of India, Criminal Appellate Jurisdiction
Case Number: Criminal Appeal Nos. 5245, 4219 of 2024 & Crl. A. Diary No. 45480 of 2024
Bench: Sudhanshu Dhulia, Prashant Kumar Mishra, JJ.
Date of Judgment: May 02, 2025

Contempt of Court – Forgery of Court Orders – Criminal Contempt – Limitation under Section 20 of Contempt of Courts Act, 1971 – Standard of Proof – Sentence Modification

Held:

  1. The appellants, convicted by the High Court of Madras for criminal contempt under the Contempt of Courts Act, 1971, for producing and creating forged interim orders of the High Court to obstruct execution proceedings, were found guilty based on cogent evidence, including affidavits, police reports, and forensic analysis.
  2. The act of producing or creating fake court orders constitutes a grave interference with the administration of justice, warranting contempt proceedings to preserve the purity of judicial processes.
  3. The contention that contempt proceedings were barred by limitation under Section 20 of the Contempt of Courts Act, 1971, was rejected. The initiation of proceedings was deemed to commence on 05.09.2018, when the High Court directed the matter to be placed before the Division Bench, within one year from the contemptuous act on 17.04.2018. Delays due to administrative issues, such as a missing case bundle, do not render proceedings time-barred.
  4. The standard of proof in criminal contempt proceedings requires establishment beyond reasonable doubt. The evidence against the appellants, including admissions and telephonic conversations, satisfied this threshold, negating claims of insufficient proof.
  5. The High Court’s finding that formal charge framing was not mandatory in contempt proceedings was upheld, as the appellants were given adequate opportunity to defend themselves, satisfying principles of natural justice.
  6. While the conviction was affirmed, the sentence of six months’ simple imprisonment was reduced to one month, considering the facts and circumstances, to meet the ends of justice.

Cases Referred:

  • In Re: Bineet Kumar Singh, (2001) 5 SCC 501
  • In Re: Vinay Chandra Mishra, (1995) 2 SCC 584
  • Pallav Sheth v. Custodian & Ors., (2001) 7 SCC 549
  • Pritam Pal v. High Court of Madhya Pradesh, (1993) Supp (1) SCC 529
  • Khushi Ram v. Sheo Vati & Anr., (1953) 1 SCC 726

Disposition: Appeals dismissed, conviction upheld, sentence modified to one month’s simple imprisonment. Appellants directed to surrender within 15 days.

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