In a stern rebuke to attempts at scandalising the judiciary, the Allahabad High Court, Lucknow Bench, has held a litigant guilty of criminal contempt for making unsubstantiated allegations of corruption against sitting judges and has imposed a fine of ₹2,000. The judgment, delivered on March 24, 2025, comes in Contempt Application (Criminal) No. 1202 of 2016, titled State of U.P. vs. Devendra Kumar Dixit.
The Division Bench comprising Justice Brij Raj Singh and Justice Vivek Chaudhary took strong exception to the complaint filed by Devendra Kumar Dixit, a resident of Lucknow, who had accused judges of accepting bribes to dismiss his writ petition.
Background: Complaint Against Judges
The matter originated from a letter dated 30 April 2016, written by Dixit and sent to the President of India, in which he alleged that his writ petition (W.P. No. 7137 (M/B) of 2016) was dismissed because the judges had allegedly taken money through Senior Advocate, acting in collusion with “corrupt and traitorous” government officials.
The complaint reached the High Court, and the then Hon’ble Acting Chief Justice, upon finding the allegations prima facie scandalous, made a reference on 9 June 2016 for initiating criminal contempt proceedings. A contempt notice was issued on 19 October 2016, marking the beginning of formal judicial action.
Legal Issues Involved
The core legal issue before the court was whether baseless, scandalous allegations made in a written complaint against High Court judges—without any supporting evidence—constituted criminal contempt under Section 2(c)(i) of the Contempt of Courts Act, 1971.
Section 2(c)(i) defines criminal contempt as publication (by words, spoken or written) which scandalizes or tends to scandalize, or lowers or tends to lower the authority of any court.
Court’s Observations and Ruling
In its detailed judgment, the court emphasized the importance of preserving the dignity and authority of the judiciary, observing:
“The contents of the complaint are clearly coming within the purview of criminal contempt. He has scandalised and lowered down the authority of the court, which amounts to interference in the administration of justice.”
The court also cited precedent from the Supreme Court’s judgment in Prashant Bhushan & Another, In Re (2021) 1 SCC 745, reaffirming that while fair criticism is permissible under Article 19(1)(a), calculated attempts to malign the judiciary cannot be tolerated.
Referring to previous contempt jurisprudence—including Shamsher Singh Bedi v. High Court of Punjab and Haryana (1996) and T. Deen Dayal v. High Court of A.P. (1997)—the bench concluded that Dixit’s letter had no bona fide basis and was aimed solely at creating distrust in the functioning of the court.
The court noted that even during the course of proceedings, the contemnor did not apologise or withdraw his remarks, and repeatedly demanded a copy of the covering letter from Rashtrapati Bhavan, even though he admitted to having authored the complaint.
While holding Devendra Kumar Dixit guilty of criminal contempt, the court exercised restraint in sentencing, noting:
“Looking to his old age and the fact that this is his first offence, we impose only a fine of ₹2,000, failing which he will undergo simple imprisonment of one week.”
The contemnor has been directed to deposit the fine before the Senior Registrar, High Court, Lucknow within one month.
