During the covid-19 pandemic, the Supreme Court of Bangladesh did not run in full swing in 2021. One of the Supreme Court lawyers showed resentment to the standoff and criticized the administrative maladroitness of the then Chief Justice by a facebook status. The Appellate Division of the Supreme Court issued contempt proceedings against the said lawyer and debarred him from practice until the proceedings is disposed of. In this background, we endeavored to explore the extent and delimitation of contempt against lawyer in this subcontinent. Hence we found a case of Privy Council where a lawyer was found guilty of contempt of court for his behavior in court room and publication of libel against the judge.

Mr. Sashi Bhushan Sarbadhicary was a barrister of Gray's
Inn and an advocate of the High Court of Judicature at Allahabad. He was suspended from practice in that court for a period of four years for “gross misconduct”.

The fact leading to the and contempt of court and suspension was that Mr. Sarbadhicary was conducting a criminal case before Richards J. (a judge of Allahabad High Court), when an altercation happened between the honourable gentleman and the counsel about the administration of the oath to the accused by the magistrate who tried them.

The Counsel assailed the court below which made the Judge angry and he said 'Why did the counsel assail the Court below?' The counsel stated that, before the files reached, the copies were the only source of his information; and sat. The judge asked the counsel to be polite, and the counsel applied (to) the judge for the same favour. The judge remarked he should not be answered back. The judge thereupon angrily said 'Sit down.'"

Following the altercation, Mr. Sarbadhicary claimed that the Judge used the word “hold your tongue” which greatly affected him. Therefore, he sent the judge a notice that" he would be legally proceeded against, both civilly and criminally, on the expiration of two months." Before this period expired, on June 1, 1906, Mr. Sarbadhicary published in a periodical called The Cochrane, of which he is both the editor and publisher, an article which has given rise to the order of suspension.

The Court held that “there is no doubt that the article in question was a libel reflecting not only upon Richards J., but other judges of the High Court in their judicial capacity and in reference to their conduct in the discharge of their public duties. There is also no doubt that the publication of this libel constituted a contempt of Court.

The Court further held that for the proper administration of justice the advocate was rightly suspended from practice for publication of libel which undoubtly constituted reasonable cause for his suspension from practice.