$~73 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(CRL) 2222/2026, CRL.M.A. 22200/2026 & CRL.M.A. 22201/2026 MADHUSUDAN AGNIHOTRI .....Petitioner Through: Mr. Anilendra Pandey and Ms. Priya Shukla, Advs. versus RIHANA & ANR. .....Respondents Through: Mr Rahul Tyagi, ASC with Mr. Sangeet Sibou, Adv. CORAM: HON'BLE MS. JUSTICE MADHU JAIN O R D E R % 28.07.2026 1. This hearing has been done through hybrid mode. 2. The present petition has been filed under Articles 226 and 227 of the Constitution of India challenging the order dated 12.01.2026 passed by the learned Civil Judge-09, Central District, Tis Hazari Courts, Delhi in Misc. SCJ No. 95/2020. By the impugned order, the application filed by the Petitioner under Section 15 read with Section 2(c) of the Contempt of Courts Act, 1971 has been dismissed. 3. The Petitioner, who is an Advocate by profession, had filed a civil suit for recovery of professional charges against the Respondents. On 16.07.2019, the Petitioner appeared before the learned Civil Judge and tendered his evidence by way of Affidavit. The matter was thereafter adjourned for his cross-examination. 4. The case of the Petitioner is that, after the court proceedings had This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 30/07/2026 at 15:46:59 concluded and while he was leaving the courtroom, the Respondents caught hold of him and assaulted him immediately outside the courtroom. It is stated that the Petitioner informed the learned Trial Court about the incident and also made a call to the police. 5. In respect of the said incident, FIR No. 171/2019 under Sections 323, 341, 506 and 34 of the IPC was registered at PS Subzi Mandi. A charge-sheet has since been filed, and the proceedings arising from the said FIR are pending before the concerned learned Metropolitan Magistrate. 6. Learned counsel for the Petitioner submits that the incident cannot be treated as a private altercation between the parties. According to him, the assault took place immediately after the Petitioner had tendered his evidence in the pending civil proceedings and was intended to intimidate and deter him from pursuing the said proceedings. 7. It is further submitted that Section 2(c) of the Contempt of Courts Act, 1971 covers not only acts which actually interfere with judicial proceedings, but also acts which tend to interfere with the due course of such proceedings or obstruct the administration of justice. On this basis, it is contended that the learned Civil Judge erred in declining to initiate criminal contempt proceedings against the Respondents. 8. This Court has heard learned counsel for the Petitioner and has perused the record. 9. There can be no dispute that an act need not bring judicial proceedings to a complete halt before it can amount to criminal contempt. An act which has a real and substantial tendency to interfere with the due course of a judicial proceeding or obstruct the administration of justice may also fall within Section 2(c) of the Contempt of Courts Act, 1971. 10. However, such interference cannot be inferred merely because the This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 30/07/2026 at 15:46:59 alleged incident took place within the court complex or near a courtroom. The place of occurrence, by itself, is not sufficient. There must be a clear link between the act complained of and the obstruction of the judicial process. 11. In the present case, even if the averments made in the petition are accepted as correct, the alleged incident took place after the Petitioner had tendered his evidence and after the proceedings before the learned Civil Judge had concluded for the day. There is no averment that the recording of evidence was interrupted, that the Court was prevented from conducting the proceedings, or that any judicial order or process was obstructed. 12. The petition also does not state that the Petitioner was thereafter prevented from pursuing the civil proceedings or that the functioning of the concerned Court was affected in any manner. The allegation that the incident was intended to intimidate or deter the Petitioner is not supported by any specific material showing that the judicial proceedings were sought to be influenced or obstructed. 13. The allegations made by the Petitioner are serious and, if proved, may attract action under the ordinary criminal law. The criminal law has already been set in motion by the registration of FIR No. 171/2019, and the allegations are the subject matter of pending criminal proceedings. 14. However, every criminal act committed within or near a court complex does not, for that reason alone, amount to criminal contempt. Contempt jurisdiction cannot be used as an additional forum to examine allegations of assault, intimidation or use of criminal force unless the act complained of has a clear and real connection with the obstruction of the administration of justice. 15. The averments in the petition, taken at their highest, disclose an alleged assault upon the Petitioner after the court proceedings had concluded. They This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 30/07/2026 at 15:46:59 do not disclose any separate act which obstructed the judicial process or interfered with the due course of the proceedings. 16. The learned Civil Judge has considered the allegations and has held that no case under Section 2(c) of the Contempt of Courts Act, 1971 is made out. This Court finds no illegality, perversity or jurisdictional error in the said conclusion warranting interference under Articles 226 or 227 of the Constitution of India. 17. The jurisdiction under Articles 226 and 227 of the Constitution of India cannot be invoked merely to seek reconsideration of the Petitioner’s request for initiation of contempt proceedings, particularly when the allegations relating to the assault are already being examined by the competent criminal court. 18. Accordingly, this Court finds no ground to interfere with the impugned order dated 12.01.2026. The present petition is dismissed. Pending application(s), if any, also stand disposed of. 19. It is clarified that this Court has not expressed any opinion on the merits of FIR No. 171/2019. The proceedings arising therefrom shall be decided independently, in accordance with law, uninfluenced by this order. 20. The order be uploaded on the website forthwith. MADHU JAIN, J JULY 28, 2026/LP/m This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 30/07/2026 at 15:46:59