| Case ID |
10ee87cc-684a-4fee-9776-d3f3505c3101 |
| Body |
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| Case Number |
Criminal Appeal No. 25 of 1954 |
| Decision Date |
Nov 08, 1955 |
| Hearing Date |
|
| Decision |
The Supreme Court held that the Commissioner appointed under the Public Servants Inquiries Act, 1850 is not a Court as defined by law. The Court concluded that the findings or reports from such inquiries lack finality and authoritativeness, which are essential characteristics of judicial pronouncements. Consequently, the appellant was not guilty of contempt as the actions taken did not constitute interference with a Court of law. The prior ruling by the High Court was reversed, and the appeal was allowed. |
| Summary |
In this landmark case, the Supreme Court of India addressed the issue of whether a Commissioner appointed under the Public Servants Inquiries Act, 1850 qualifies as a Court for the purposes of the Contempt of Courts Act, 1952. The case arose from a complaint against a Deputy Secretary who had written a letter to the Commissioner, which was alleged to have interfered with the inquiry into the respondent's conduct as a public servant. The Court examined the definitions of 'Court' and 'judicial power' across various statutes, emphasizing the necessity of finality and authoritativeness in judicial decisions. Ultimately, the Supreme Court ruled that the Commissioner was not a Court, thereby reversing the High Court's decision that had found the appellant guilty of contempt. This case is significant in understanding the delineation between administrative inquiries and judicial proceedings, and it emphasizes the importance of adhering to the definitions established in law regarding the powers and functions of different bodies. |
| Court |
Supreme Court of India
|
| Entities Involved |
Not available
|
| Judges |
BHAGWATI, J.,
SINHA, J.,
IMAM, J.
|
| Lawyers |
M. C. Setalvad, Attorney General of India,
Mahabir Prasad, Advocate General of Bihar,
Purshottam Trikamdas, Senior Advocate,
R. Patnaik, Advocate
|
| Petitioners |
BRAJNANDAN SINH
|
| Respondents |
JYOTI NARAIN
|
| Citations |
1956 SLD 34,
1956 PLD 65
|
| Other Citations |
A I R 1954 Pat. 289,
A I R 1951 Panj. 49,
1931 A C 275,
(1909) 8 C L 330,
(1924) 1 K B 171,
1950 S C R 730,
(1937) 2 K B 309,
1954 S C R 1150,
(1892) 1 Q B 431,
(1873) 8 Q B 255,
(1875) H L 744,
A I R 1954 Nag. 71
|
| Laws Involved |
Contempt of Courts Act (1952),
Public Servants (Inquiries) Act (XXXVII of 1850),
Penal Code (XLV of 1860),
Evidence Act (1 of 1872)
|
| Sections |
3,
19,
20,
3
|