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Issues Involved:
1. Whether the Commissioner appointed under Act XXXVII of 1850 is a Court. 2. Whether the Commissioner appointed under the Act is a Court subordinate to the High Court within the meaning of the Contempt of Courts Act. 3. Whether the letter complained against constituted a contempt of Court. Issue-wise Detailed Analysis: 1. Whether the Commissioner appointed under Act XXXVII of 1850 is a Court: The appeal arose from an application under section 2 of the Contempt of Courts Act and section 8 of the Public Servants (Inquiries) Act, read with article 227 of the Constitution. The primary question was whether the Commissioner appointed under Act XXXVII of 1850 is a Court. The respondent, a Member of the Bihar Civil Service, was accused of misconduct, and an inquiry was initiated under the Public Servants (Inquiries) Act. The Commissioner, Mr. Anjani Kumar Saran, was appointed to conduct the inquiry. The High Court had held the Commissioner to be a Court and found the appellant guilty of contempt for writing a letter to the Commissioner, urging vigilance against the respondent's dilatory tactics. The Supreme Court analyzed the definition of "Court" and concluded that the essential condition for a body to be considered a Court is the power to give a definitive judgment with finality and authoritativeness. Referring to previous judgments and legal definitions, the Court noted that the Commissioner's role was primarily a fact-finding mission without the power to pronounce binding judgments. The Commissioner's findings were only recommendations to the Government, lacking finality and authoritativeness. Thus, the Commissioner did not constitute a Court within the meaning of the Contempt of Courts Act. 2. Whether the Commissioner appointed under the Act is a Court subordinate to the High Court within the meaning of the Contempt of Courts Act: Given the conclusion that the Commissioner is not a Court, the question of subordination to the High Court became irrelevant. The Supreme Court did not find it necessary to address this issue in detail, as the primary determination that the Commissioner is not a Court rendered further analysis unnecessary. 3. Whether the letter complained against constituted a contempt of Court: Although the Supreme Court did not delve deeply into this issue due to the resolution of the primary question, it noted in passing that the circumstances surrounding the letter, its content, and the Commissioner's response did not support the argument that it constituted contempt of Court. The Commissioner himself had rejected the respondent's application to start contempt proceedings against the appellant, indicating that the letter did not interfere with the Commissioner's judicial functions. Conclusion: The Supreme Court allowed the appeal, setting aside the High Court's order against the appellant. The original Criminal Miscellaneous Petition filed by the respondent in the High Court was dismissed, and any fine paid by the appellant was ordered to be refunded.
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