Introduction

In a reportable exercise of its inherent jurisdiction in a suo motu contempt proceeding, the Supreme Court of India (B.R. Gavai, CJI and K. Vinod Chandran, J.) has delivered a significant judgment in In Re: N. Peddi Raju and Others, Suo Motu Contempt Petition (Civil) No. 3 of 2025, decided on 10 November 2025. The case arose from Transfer Petition (Criminal) No. 613 of 2025 in which the petitioner and his legal team used scurrilous and scandalous language against a sitting Judge of the High Court of Telangana. When confronted, the petitioner sought to withdraw the transfer petition; the Supreme Court, however, refused to permit withdrawal, issued contempt notices to the petitioner, the Advocate-on-Record (AOR), and the drafting counsel, and ultimately fashioned a restorative pathway centered on unconditional apology to the aggrieved High Court Judge.

The judgment reinforces enduring constitutional and professional principles: the Bar’s status as “officers of the court,” the impermissibility of scandalizing the judiciary through pleadings, and the sober balance between deterrence and forgiveness in contempt jurisprudence. It also articulates a practical approach in such cases—an apology first tendered to the targeted judge—before the Supreme Court considers closure.

Case Background and Parties

• Alleged contemnors:
  • Alleged Contemnor No. 1: Mr. N. Peddi Raju (the petitioner in the transfer petition)
  • Alleged Contemnor No. 2: Mr. Ritesh Patil (Advocate-on-Record for the petitioner)
  • Alleged Contemnor No. 3: Mr. Nitin Meshram (counsel who drew/drafted the transfer petition)
• Trigger: Transfer Petition (Criminal) No. 613 of 2025 containing scurrilous allegations against a sitting Judge of the High Court of Telangana.
• Bench: B.R. Gavai, CJI (authoring) and K. Vinod Chandran, J.
• Proceeding type: Suo motu contempt under the Court’s inherent jurisdiction.

Timeline

• 29.07.2025: Supreme Court refuses permission to withdraw the transfer petition; dismisses it; issues notice to show cause for contempt to petitioner, AOR, and drafting counsel.
• 11.08.2025: Hearing on contempt notices; apologies tendered; the Court directs that apology be first tendered to the concerned High Court Judge. Registrar General of the High Court directed to reopen disposed Criminal Petition No. 4162 of 2020 solely to facilitate the apology.
• 22.08.2025: Learned Single Judge of the High Court accepts the apology and records strong observations deprecating the trend of vilifying judges.
• 10.11.2025: Supreme Court accepts the apologies in light of the High Court Judge’s acceptance; contempt proceedings closed with cautionary observations to the Bar.

Summary of the Judgment

The Supreme Court identified a troubling pattern: when litigants or lawyers do not receive favorable orders, they sometimes resort to scandalous allegations against judges in court filings. The Court refused to allow the withdrawal of the offending transfer petition, emphasizing that such a tactic cannot shield parties from contempt consequences. It issued show cause notices to the petitioner, the AOR, and the drafting counsel.

When apologies were tendered before the Supreme Court, the Bench held it would be more appropriate for the contemnors to first apologize to the judge who was targeted. The Court directed the reopening of a disposed High Court matter solely for the limited purpose of placing the unconditional apology before the concerned Judge. The Judge accepted the apologies and recorded strong remarks about the harm of vilifying judges and the special responsibility of advocates in safeguarding the dignity of courts.

In view of the High Court Judge’s magnanimity and acceptance of the apologies, and drawing upon a recent three-judge bench order stressing forgiveness in contempt where wrongdoers genuinely repent, the Supreme Court accepted the apologies and closed the proceedings. At the same time, it reiterated, with reliance on foundational precedent, that advocates who sign pleadings with scandalous material against judges may themselves be guilty of contempt unless they have reasonably verified a prima facie basis for such allegations. The Court issued a caution to the Bar to be scrupulous when subscribing to pleadings containing allegations against judges.

Analysis

Precedents Cited and Their Influence

The Court’s reasoning is anchored in established doctrine and the advocates’ ethical duties, supported by the following authorities:

• M.Y. Shareef v. Hon’ble Judges of the High Court of Nagpur (1954) 2 SCC 444:

  A Constitution Bench decision addressing counsel’s responsibility when signing pleadings that allege bias or impropriety. The Supreme Court quotes the case’s core teaching: a segment of the Bar mistakenly assumes that following client instructions excuses them from their duty to the court. Shareef articulates an emphatic corrective—counsel who sign applications containing scandalous matter without reasonably satisfying themselves of a prima facie basis, especially to delay or derail justice, are themselves guilty of contempt. It further recognizes that where the Bar labors under a misconception, a qualified apology in “borderline cases” may merit consideration.

  Influence on the present case: The Supreme Court relies on Shareef to reaffirm that advocates’ duty to the court can and does override client instructions, and that signing scandalous pleadings can attract contempt. This explains why the AOR and the drafting counsel were also proceeded against, not just the petitioner.

• In the matter of T.V. Choudhary (1987) 3 SCC 258 (with references to Rondel v. Worsley and observations by Lord Denning):

  T.V. Choudhary reiterates the Bar’s dual obligation—to the client and to the court—with primacy of the latter when in conflict. The Court quotes from Rondel v. Worsley (1967) 3 All ER 993 (HL) and from Lord Denning, emphasizing that counsel must not mislead the court, must refrain from baseless aspersions, and must be prepared to act against a client’s specific instructions if those instructions are inconsistent with counsel’s duty to the court. The “code of honour” of the Bar requires such fidelity to the court’s integrity.

  Influence on the present case: These classic formulations supply the ethical foundation for the Court’s deprecation of scurrilous pleadings. They also justify the Court’s insistence that senior and junior counsel alike model detachment, restraint, and respect for judicial institutions—particularly in the drafting and settling of pleadings.

• N. Eswaranathan v. State (MA No. 1264 of 2025 in SLP (Crl.) No. 6029 of 2025, order dated 23 July 2025):

  A three-judge bench (including the present CJI and K. Vinod Chandran, J.) recently addressed sentencing in contempt proceedings against two lawyers, with the bench endorsing the principle that “the majesty of law lies not in punishing someone, but in forgiving someone who acknowledges their mistake.” The Court preferred leniency where unconditional apologies were offered and accepted.

  Influence on the present case: This principle informs the present closure. Because the High Court Judge accepted the unconditional apologies, the Supreme Court followed suit. Eswaranathan thus guides the sanctioning philosophy: genuine contrition and acceptance by the victim judge favor restorative over retributive measures.

Legal Reasoning and Doctrinal Threads

• Refusal to allow withdrawal as a shield: The Court’s decision not to permit withdrawal of the transfer petition prevented the contemnors from evading accountability. This sends a clear message: the act of filing scandalous allegations is itself actionable; merely retreating from the pleading does not expiate the contempt nor sanitize the abuse of process.
• Shared responsibility of the petitioner, AOR, and drafting counsel: Consistent with Shareef, liability for contempt can attach not only to the signatory party but also to legal professionals who settle or draft the offending pleadings. The Court’s notices to all three reflect an expectation that advocates will exercise gatekeeping judgment and refuse to put their signatures to scandalous averments lacking a reasonable prima facie foundation.
• “First apologize to the aggrieved judge” approach: Recognizing the personal and institutional harm caused by vilification, the Court considered it “more appropriate” that the apology be made first to the judge who was maligned. It directed the High Court’s Registrar General to reopen a disposed matter exclusively to enable the apology. This limited reopening preserved procedural finality while accommodating restorative justice and dignitary interests of the affected judge.
• Balancing denunciation with restoration: The judgment strongly deprecates the growing trend of vilifying judges in pleadings—a trend the High Court Judge also condemned in forthright terms—yet it ultimately privileges contrition over punishment. With the apology accepted by the High Court Judge, the Supreme Court accepted the apology and closed proceedings, while issuing a cautionary note to the Bar.
• Reaffirmation of the advocate’s “overriding duty to the court”: Drawing from T.V. Choudhary and Rondel v. Worsley, the Court stresses that an advocate’s first allegiance is to the court’s integrity. This has concrete consequences: lawyers must verify allegations against judges and decline client instructions that would compromise the court’s dignity or the profession’s ethical code.

Impact and Prospective Effects

• Deterrence against “judge-shopping” through vilification: The refusal to permit withdrawal and the issuance of contempt notices signal that courts will not countenance tactical abuse of transfer petitions by defaming judges. Expect heightened scrutiny of transfer petitions that contain allegations impugning a judge’s motives or impartiality without substantiation.
• Practical protocol for apologies in judge-targeted contempt: While not framed as a formal practice direction, the Court’s endorsement of first apologizing to the aggrieved judge will likely serve as a template in similar cases. It respects the dignity of the individual judge, facilitates closure, and may reduce the adversarial temperature in contempt matters.
• Increased professional accountability for AORs and drafting counsel: The inclusion of the AOR and drafting counsel underscores that professional responsibility extends to what advocates sign or settle. Law offices may respond by instituting enhanced internal review protocols for pleadings that mention judicial conduct, including double-checks by seniors and documentary substantiation where permissible.
• Restorative emphasis in contempt sentencing: Reinforced by Eswaranathan, the Court’s preference for forgiveness where apology is genuine and accepted could shape future contempt outcomes, particularly where the offense consists of scandalous pleadings rather than disobedience of court orders. That said, the present judgment’s cautionary tone indicates that leniency is not guaranteed; absence of repentance or repetition may invite sterner measures.
• Bar’s educative moment: The judgment can be expected to inform continuing legal education and bar association advisories, highlighting that duties to court are not theoretical; they carry real consequences in drafting and advocacy. Senior counsel, as role models, are reminded to exemplify restraint and detachment.
• Social media and public commentary by lawyers: Though the case concerns court pleadings, the High Court Judge’s remarks about vilification “in print or on social media” warn that extrajudicial campaigns against judges corrode public trust. Professional standards apply across platforms; irresponsible allegations risk both contempt proceedings and disciplinary action.

Complex Concepts Simplified

• Suo motu contempt: Proceedings initiated by the court on its own motion (without a formal complaint) to address acts that scandalize the court, obstruct justice, or lower the authority of the judiciary.
• Scandalizing the court: Using baseless, scurrilous allegations against judges or courts that tend to undermine public confidence in the administration of justice. Such conduct can constitute contempt even if the form is a pleading.
• Advocate-on-Record (AOR): In the Supreme Court, only AORs may file pleadings. Their signature carries a special responsibility to ensure that the content meets professional and legal standards.
• Unconditional apology: A sincere admission of wrongdoing without qualification or justification. In contempt jurisprudence, a genuine unconditional apology can mitigate or avert punitive sanctions.
• Limited reopening of a disposed matter: Here, the High Court’s concluded case was reopened only to receive the apology. This narrow reopening served an ethical and restorative function without revisiting the case’s merits.
• Duty to court versus duty to client: Advocates must represent clients fearlessly, but when client instructions clash with the advocate’s duties to the court and to the profession, the advocate must prioritize the latter—refraining from filing or endorsing scandalous or unsubstantiated allegations.

Practical Guidance for the Bar

• Before alleging bias or impropriety by a judge, ensure a reasonable prima facie foundation; if in doubt, advise the client against making such allegations.
• Remove adjectives and rhetoric from pleadings; state material facts with precision and sobriety.
• Use appropriate procedural avenues (e.g., recusal applications) respectfully, without imputing motives unless strictly necessary and supported.
• Senior counsel settling pleadings should treat this as a heightened responsibility; internal peer review for sensitive drafts is advisable.
• If an error is made, act promptly to apologize; where a judge has been personally maligned, consider tendering the apology first to that judge.
• Educate junior colleagues on the “overriding duty to the court” and the consequences of scandalous pleadings.

Conclusion

In Re: N. Peddi Raju (2025 INSC 1321) is a careful blend of censure and clemency. It reaffirms that:

• Scurrilous, scandalous allegations in pleadings against judges can constitute contempt not only by parties but also by the advocates who sign or settle them.
• Withdrawal of an offending pleading is not a safe harbor from contempt; accountability persists.
• Where the wrongdoers are contrite, a restorative route—apology first tendered to the aggrieved judge—can be appropriate and effective.
• The majesty of law is served not by automatic punishment but, where suitable, by magnanimity in accepting apologies and focusing on institutional dignity and public confidence.

The judgment’s broader significance lies in its sustained emphasis on the advocate’s “overriding duty to the court.” By grounding its approach in classical authority and contemporary experience, the Supreme Court has both warned and guided the profession: zealous advocacy cannot license vilification; professional honor requires restraint, verification, and respect. Where contrition is real and the harmed judge accepts it, the system may—without compromising its integrity—choose forgiveness.

Case Citation and Bench

• Case: In Re: N. Peddi Raju and Others, Suo Motu Contempt Petition (Civil) No. 3 of 2025
• Citation: 2025 INSC 1321
• Court: Supreme Court of India (Reportable)
• Date of Decision: 10 November 2025
• Bench: B.R. Gavai, Chief Justice of India; K. Vinod Chandran, J.