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12. The general principle of law in this regard is that whenever there is a Special Act enacted in respect of limitation, the powers conferred under the Constitution as well as the Special Act to be read cogently and harmoniously. Harmonious reading of these provisions, no doubt, the High Courts are empowered to exercise the power of contempt as the High Court is the Court of record. However, such power can be exercised only with reference to Section 20 of the Contempt of Courts Act. This will not mean that, the High Courts cannot exercise the powers of contempt beyond the limitation period of one year. The powers of contempt beyond the limitation period can be exercised only on exceptional circumstances, and sparingly. The powers conferred under the Constitution in normal circumstances are to be exercised only with reference to the Special Act viz., the Contempt of Courts Act. Only in extraordinary circumstances; the High Courts can go beyond the period of one year and exercise the powers of Contempt under Article 215 of the Constitution of India. The practice prevailing now is that, irrespective of the period limitation prescribed under Section 20 of the Contempt of Courts Act, the contempt applications are filed in a routine manner by stating that no limitation is applicable in respect of the contempt applications filed before the High Courts. Such a concept is not in accordance with the legal principles settled in this regard.

17. Article 215 of the Constitution of India empowers every High Court to punish contempt of Court subordinate to it, but Contempt of Courts Act lays down how that power is to be exercised. Article 215 and provisions of the Contempt of Courts Act have to be read together. The Honble Apex Court has emphasized that Section 20 applies to civil and criminal contempts and would also apply to the contempt committed on the face of High Court or the Supreme Court or even Subordinate Courts. Where there is a limitation for initiation of proceedings of contempt under Section 20 of the Act, the Rules of Code provide that no notice shall be issued if more than one year has lapsed from the alleged act of contempt.

21. The Supreme Court of India held in this regard that the proper construction to be placed on Section 20 must be that the action initiated either by filing of an application or by the Court issuing notice suo moto, within a period of one year from the date on which the contempt is alleged to have been committed. No doubt, the High Court is not powerless even when the period of one year is expired from the date of alleged violation of Court's order, the Courts can exercise its inherent power under Article 215 of the Constitution of India. However, such powers ought to be exercised only on exceptional circumstances, more so to mitigate the gross in justice if any occurred and the inherent powers ought to be exercised sparingly and not in a routine manner. The High Courts cannot make the limitation period prescribed under Section 20 of the Contempt Courts Act illusory. The limitation prescribed under Section 20 is to be scrupulously followed in all cases and the provisions as to be read harmoniously along with Article 215 of the Constitution of India. One step further this Court has to emphasize that the Contempt of Courts Act is a Special Act and the same will prevail in respect of filing of the contempt application under the very same Act. The general powers conferred under the Constitution has to be read along with the provisions of the contempt of Courts Act. The Act is to be construed as the procedure for initiating contempt contemplated, by virtue of the powers conferred under the constitution.

31. The High Court's cannot invoke the powers under Article 215 of the Constitution of India, in all the cases by entertaining the contempt application beyond the period of one year, so as to dilute or eradicate the law prescribed under Section 20 of the Contempt of Courts Act, 1971. All contempt applications ought to be filed within the period of limitation prescribed under Section 20 of the Contempt of Courts Act, 1971. The High Court on exceptional circumstances, on arriving a conclusion that a gross injustice to the society or the case is of public importance, then the inherent powers provided under Article 215 of the Constitution of India, can be exercised without reference to Section 20 of the Contempt of Courts Act. A litigant may come out with an interpretation that an injustice is caused to all the orders or judgements passed by the High Courts. Such a general proposition, as advanced by the learned counsel appearing for the petitioner deserves no merit consideration. No doubt, the litigants approach the Court to get justice, that does not mean that all the contempt applications have to be entertained after a period of one year prescribed under Section 20 of the Contempt of Courts Act, 1971. Generalisation in this regard can never be encouraged. What exactly the circumstances warranting interference under Article 215 of the Constitution of India has to be decided judiciously and applying the peculiar facts and circumstances prevailing in each and every case. General application in this regard is certainly impermissible and Courts have to interpret these provisions in a pragmatic way than in a general manner. In other words, the principles of constructive interpretation is to be adopted while interpreting the period of limitation under Section 20 of the Contempt of Courts Act as well as Article 215 of the Constitution of India. Thus, this Court is not inclined to consider the arguments advanced by the learned counsel appearing for the petitioner by citing the above judgement of the Hon'ble Supreme Court.