Sincere Remorse Cleanses Contempt: Telangana High Court’s Restorative Approach to Scandalous Transfer Pleadings and the Bar–Bench Compact

Introduction

This commentary examines the Telangana High Court’s order dated 22 August 2025 in Criminal Petition No. 4162 of 2020, titled “Anumula Revanth Reddy v. The State of Telangana,” delivered by Justice Moushumi Bhattacharya. The order, though arising within a larger criminal quashment proceeding related to a Special Sessions case under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (as amended), is narrowly focused on a collateral but constitutionally significant issue: contemptuous pleadings in a Transfer Petition filed before the Supreme Court and the acceptance of unconditional apologies tendered by three alleged contemnors—(i) Mr. N. Peddi Raju (the de facto complainant), (ii) Mr. Ritesh Patil (Advocate-on-Record, Supreme Court of India), and (iii) Mr. Nitin Meshram (the advocate who drafted the transfer petition).

The immediate trigger was a Supreme Court judgment dated 11 August 2025 in Suo Motu Contempt Petition (Civil) No. 3 of 2025, in which the apex court, presided over by the Chief Justice of India, took exception to scandalous allegations in a transfer pleading that sought to move the High Court matter on a claim of judicial partiality and alleged curtailment of hearing. Pursuant to directions issued by the Supreme Court, the High Court reopened the disposed criminal petition on 19 August 2025 for the limited purpose of considering the contemnors’ affidavits of apology, which were tendered by email on 21 August 2025.

At the heart of this order lies a normative statement of judicial philosophy: criticism of judgments is part of the legal process, but personal attacks on judges are not. The decision crystallizes the idea—expressed in unmistakably clear terms—that “an expression of sincere remorse has the effect of cleansing the scandalous act,” and that the authority of courts stems “not from retaliation or the power to penalize and punish, but the power to balance the scales of justice.”

Summary of the Judgment

The High Court reopened Criminal Petition No. 4162 of 2020 pursuant to the Supreme Court’s 11 August 2025 judgment, limited to considering the contemnors’ affidavits of apology.
Three alleged contemnors were involved:
- Mr. N. Peddi Raju (de facto complainant): tendered apology before the Supreme Court and, as directed, before the High Court.
- Mr. Ritesh Patil (AOR, Supreme Court): expressed regret for the language used; acknowledged that he signed and filed the pleading without detecting the offensive remarks.
- Mr. Nitin Meshram (drafting advocate): accepted responsibility for drafting the transfer petition; tendered unconditional apology; recorded that an attempt to withdraw the petition was not permitted by the Supreme Court.
The Court recorded that the allegation of the de facto complainant regarding being given “only five minutes” of hearing before the High Court is contrary to the record.
The Court articulated:
- Proper hearing is an indispensable part of judicial decision-making; the Bar–Bench dialogue is an expression of mutual respect and a common quest for justice.
- While criticism of judgments is permissible, imputations of bias or collateral motives against a judge scandalize the court and corrode the trust between court and counsel.
- Criminal contempt includes acts that scandalize or lower the authority of the court; sincere remorse can cleanse the scandalous act.
- Vilification of judges—especially via social media—is an emerging trend that threatens judicial independence and impartiality.
- Judgeship is about responsibility and conscience, not the power of office.
Outcome: The High Court accepted the unconditional apologies of all three alleged contemnors and directed that the matter be placed before the Supreme Court in accordance with the apex court’s directions.

Analysis

Precedents Cited

The order explicitly anchors itself to the Supreme Court’s judgment in Suo Motu Contempt Petition (Civil) No. 3 of 2025, which occasioned the reopening of the High Court proceedings and framed the remit for considering the affidavits of apology. No other specific case citations are enumerated in the High Court’s order. The Court’s definitional observation that “Contempt of Court includes Criminal Contempt which encompasses any act which scandalises or tends to scandalise, or lowers or tends to lower the authority of, any Court” aligns with Section 2(c) of the Contempt of Courts Act, 1971, and its long-settled judicial exposition.

Although not cited, the Court’s approach resonates with an established body of Indian jurisprudence which draws a clear line between permissible criticism of judicial decisions and impermissible scandalizing of the court or imputations of bias:

Brahma Prakash Sharma v. State of Uttar Pradesh (AIR 1954 SC 10): early articulation that “scandalizing the court” is contempt when it tends to lower the authority of the court or interfere with the administration of justice.
Baradakanta Mishra v. Registrar of Orissa High Court (1974) 1 SCC 374: explained that allegations imputing improper motives to judges constitute contempt.
P. N. Duda v. P. Shiv Shankar (1988) 3 SCC 167: drew a distinction between fair criticism in public interest and contemptuous attacks that impair the administration of justice.
In Re: Arundhati Roy (2002) 3 SCC 343 and In Re: Prashant Bhushan & Anr. (2020): recent reaffirmations of the contours of contempt arising from public statements and social media.
M.Y. Shareef v. Hon’ble Judges of the Nagpur High Court (1955) 1 SCR 757 and L.D. Jaikwal v. State of U.P. (1984) 3 SCC 405: principles on acceptance of apologies—only genuine, unconditional remorse can purge contempt; a tactical apology does not.

These authorities are referenced here as background jurisprudence; they are not cited in the order under review.

Legal Reasoning

The Court’s reasoning is layered, blending doctrinal fidelity with institutional values:

Jurisdictional posture: The High Court reopened a disposed matter solely to comply with the Supreme Court’s directions, reflecting institutional comity and vertical judicial coordination. This also underscores the apex court’s supervisory role when contempt concerns arise from pleadings filed before it.
Fact-finding bounded by the record: The Court expressly records that the allegation of curtailed hearing time (“only five minutes”) is contrary to the record. This is significant: it signals that transfer pleas premised on judicial bias or procedural unfairness must be supported by the transcript and the docket, not by subjective impressions.
Contours of contempt: The order restates the classic definition of criminal contempt—acts that scandalize the court or tend to lower its authority—and applies it to pleadings alleging partiality and collateral motives. Particularly notable is the Court’s reminder that criticism of judgments is an intrinsic part of the legal process, but personal attacks on judges rupture the implicit trust between court and officers of the court.
Restorative over punitive: The fulcrum of the decision is the acceptance of unconditional apologies on the footing that “an expression of sincere remorse has the effect of cleansing the scandalous act.” The Court thus emphasizes the purgative function of genuine contrition, consistent with the proviso to Section 12(1) of the Contempt of Courts Act (which permits discharge or remission on apology if bona fide).
Bar–Bench compact: The order treats “hearing” as a shared enterprise—the “ongoing dialogue” that dissolves the boundary between Bar and Bench in a common quest for justice. By highlighting this compact, the Court frames personal vilification as a breach not only of decorum but of a necessary institutional trust that enables impartial adjudication.
Institutional harm and social media: The Court notes a contemporary “trend of vilifying Judges,” exacerbated by the ease of dissemination on social media, and the asymmetry that judges do not have a platform to respond. This observation extends the contempt analysis beyond courtroom pleadings to the modern ecosystem of public communication where contempt may be aggravated.
Proportional disposition: Having obtained and scrutinized the affidavits—each acknowledging responsibility in calibrated ways—the Court concludes that acceptance of apology suffices. This measured closure avoids escalation, while preserving the record that the allegation about hearing was incorrect.

Impact

The order’s likely effects will be felt across several axes of practice and doctrine:

Pleadings discipline in transfer petitions: Counsel will need to ensure that claims of bias or procedural unfairness are anchored in the record, employ restrained language, and eschew imputation of motives. The decision signals zero tolerance for scandalous averments in transfer petitions, a genre prone to emotive framing.
Responsibility of signatories and drafters: The Court recites candid acknowledgments by the drafting counsel and the AOR. By noting that an AOR “failed to notice” offensive language, the order implicitly reminds officers of the court that signatures are certifications; both drafters and signatories bear responsibility for pleadings’ contents.
Restorative justice in contempt: The statement that sincere remorse “cleanses” the scandalous act reinforces a jurisprudential preference for reformative responses to contempt, especially when the contemnors unequivocally accept fault. This may encourage early contrition and reduce adversarial escalation in future contempt matters.
Bar–Bench relations and professional ethics: The strong emphasis on respectful dialogue and the denunciation of personal attacks may inform bar council advisories, continuing legal education, and internal law firm protocols for sensitive pleadings.
Social media caution: The order’s observations about the “flick of a key” phenomenon caution practitioners and litigants that online commentary about ongoing proceedings and judges can cross into contempt.
Institutional comity with the Supreme Court: The High Court’s deference to Supreme Court directions and the instruction to place the matter back before the apex court model a template for managing cross-court contempt fallout, ensuring procedural coherence and finality at the appropriate level.
Procedural baselines on hearing: By branding the “five-minute hearing” claim as “contrary to the records,” the order affirms that fairness claims must be evidence-backed. This may influence how future allegations of curtailed hearing are evaluated, especially when used to justify transfer or recusal applications.

Complex Concepts Simplified

Criminal Petition under Section 482 CrPC: This is a petition invoking the High Court’s inherent powers to prevent abuse of process or to secure the ends of justice, often used to seek quashing of criminal proceedings. The underlying criminal matter here involves a Special Sessions case under the SC/ST (POA) Act.
SC/ST (POA) Act Special Court: Offences under the Act are tried by Special Courts; transfer and quash petitions involving such cases are sensitive because they intersect with statutory protections for vulnerable communities.
Transfer Petition: A petition seeking transfer of a case from one court to another—here, from the Telangana High Court—usually on grounds such as reasonable apprehension of bias or convenience. Allegations must be sober, reasoned, and supported by record.
Suo motu contempt: Latin for “on its own motion.” The Supreme Court or a High Court can initiate contempt proceedings without a formal complaint if it perceives an act that undermines the administration of justice—such as scandalous pleadings filed before it.
Criminal Contempt: Under the Contempt of Courts Act, 1971, this includes any act that “scandalises or tends to scandalise, or lowers or tends to lower the authority of, any court,” or interferes with judicial proceedings or administration of justice.
Affidavit of Apology: A sworn statement expressing remorse and accepting responsibility, often tendered by an alleged contemnor to purge the contempt. Courts assess sincerity; tactical or qualified apologies can be rejected.
Bar–Bench dialogue: The professional interaction in court where counsel present arguments and judges test them with questions. It is foundational to due process. Dissatisfaction with outcomes should be channeled via recall/review/appeal—not via personal allegations against judges.
BNSS reference: The record notes an application under Section 529 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (the statute that has replaced the Code of Criminal Procedure). That application sought to vacate an interim order, but the present order does not adjudicate it; the order is confined to the contempt-related issue and the acceptance of apologies.

Key Observations Worth Quoting

“Giving a proper hearing to counsel as the representative of a litigant is also an expression of respect… [and] merges into a common quest for justice.”
“While criticizing a judgment is part of the legal process, personal attacks on a Judge on allegations of bias and collateral motives rupture the implicit trust between the Court and the officers of the Court.”
“An expression of sincere remorse has the effect of cleansing the scandalous act on the part of the alleged Contemnor.”
“The authority of the Court stems, not from retaliation or the power to penalize and punish it, but the power to balance the scales of justice.”
“A trend of vilifying Judges has emerged in recent times… Such reckless allegations derail the course of justice.”
“Judgeship is never about the power of the Chair but is always about the responsibility of disseminating justice with conscience, commitment and compassion.”

Conclusion

This order is a carefully calibrated response to a modern and pressing challenge in the administration of justice: the drift from robust criticism of decisions to personalized vilification of judges in court filings and online fora. The Telangana High Court reaffirms foundational commitments—due hearing, Bar–Bench respect, and measured language—while choosing a restorative path in contempt adjudication by accepting unambiguous apologies that acknowledge responsibility.

Three takeaways stand out:

Record, not rhetoric, decides fairness. Allegations about curtailed hearing or partiality must be borne out by the transcript and docket; otherwise, they risk crossing into contempt.
Officers of the court shoulder non-delegable responsibility. Drafters and signatories alike must cleanse pleadings of insinuations and ensure that transfer petitions rest on objective, verifiable grounds.
Sincere remorse matters. The Court’s express recognition that genuine apology can “cleanse” a scandalous act foregrounds a reformative ethic, preserving judicial authority without resorting to punitive maximalism.

Placed against the backdrop of the Supreme Court’s suo motu intervention, the order exemplifies institutional comity and principled restraint. It will likely shape bar practice in transfer petitions and beyond, reinforcing that while criticism of judgments is protected and even essential, personal attacks on judges are not. In this sense, the decision is more than a case resolution; it is a restatement of the Bar–Bench compact that underwrites the rule of law.