Shanmugam @ Lakshminarayanan vs High Court Of Madras 2025 INSC 619 - Contempt - Create Fake Court Orders - Limitation

Contempt of Courts Act 1971- Creating fake orders of the Court is one of the most dreaded acts of contempt of court. It not only thwarts the administration of justice, but it has inbuilt intention by committing forgery of record. (Para 16) The sole object of the Court wielding its power to punish for contempt is always for maintaining the purity of administration of justice. Nothing is more incumbent upon the courts of justice than to preserve their proceedings from being misrepresented, nor is there anything more pernicious when the order of the court is forged and produced to gain undue advantage. A misleading or a wrong statement deliberately and wilfully made by a party to the proceedings to obtain a favourable order would undoubtedly tantamount to interference with the due course of judicial proceedings. When a person is found to have utilised an order of a court which he or she knows to be incorrect for conferring benefit on persons who are not entitled to the same, the very utilisation of the fabricated order by the person concerned would be sufficient to hold him/her guilty of contempt, irrespective of the fact whether he or she himself or herself is the author of fabrication. (Para 8)

Contempt of Courts Act 1971- Section 20 - The contempt action must be initiated either by filing of an application or by the Court issuing notice suo motu within a period of one year from the date on which the contempt is alleged to have been committed. The originating point for calculating the period of limitation has been - (Para 14) the date of initiation of suo motu contempt action is regarded as the initiation by the Court for the purpose of Section 20. (Para 15) - Referred to Pallav Sheth vs. Custodian (2001) 7 SCC 549.

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