Allahabad HC Converts Review Petition into Criminal Contempt Case After Petitioner Uses Contemptuous Language Against Single Judge
Chief Justice Arun Bhansali and Justice Kshitij Shailendra found a pro se petitioner's review pleadings contemptuous of a Single Judge and directed registration of a criminal contempt petition.
On 13 August 2026, the Division Bench of the High Court of Judicature at Allahabad — comprising Chief Justice Arun Bhansali and Justice Kshitij Shailendra — declined to hear a review petition on its merits and directed the Registry to register the matter afresh as a criminal contempt petition. The petitioner, Vishram Singh, had filed the review application in person against an order dated 9 July 2026, by which Special Appeal Defective No. 488 of 2026 had been dismissed as not maintainable. The bench found that the written pleadings in the review petition contained language directly targeting the learned Single Judge whose judgment had been the subject of that dismissed appeal, and that such language was contemptuous on its face.
The Proceedings That Led to the Review Application
Vishram Singh had approached the Division Bench by way of a special appeal, challenging a judgment of a learned Single Judge of the same court. That special appeal was dismissed as not maintainable by the court's order of 9 July 2026. Singh, appearing in person throughout, then filed Civil Misc Review Application Defective No. 231 of 2026 before the Chief Justice's Court, seeking review of the order dismissing his appeal.
The opposite parties were represented by counsel including the Government Counsel, a Government Advocate, and senior advocate Manish Goyal along with other counsel. Singh contested the proceedings without any legal representation.
What the Review Petition Contained
The Division Bench, on examining the review petition, found it “replete of language qua the learned Single Judge” whose judgment had been the subject of the dismissed appeal. The bench extracted several passages from the petition, written in Hindi, to record what it considered contemptuous content.
The extracted passages characterised the Single Judge's order as one issued fraudulently and without jurisdiction, used phrases such as “dhokhe se jaari aadesh” (orders issued through deceit) and “aavaida jaari aadesh” (illegal orders), and described the judicial act as a “kootrachit shadyantrakaari aadesh ki rachna” — the crafting of a fraudulently conspired order. One passage framed the dismissal of the petitioner's appeal as an act of deceiving him by denying justice through what it called a fabricated and conspiratorial order.
The bench reproduced the offending passages in the order to place on record the precise language that prompted its direction, leaving no ambiguity about which portions of the petition were found objectionable.
The Court's Reasoning
The Division Bench did not engage with the merits of the review at all. It confined its reasoning to the character of the language used in the petition itself. The court held that the petitioner, by using such language, had “attempted to lower down the dignity of this Court.” It treated the written pleadings, directed as they were against a sitting judge of the same court, as amounting to criminal contempt.
The bench made clear that the route taken — directing fresh registration as a criminal contempt petition — was a consequence of the language in the petition and not of the underlying dispute about the maintainability of the special appeal. The review petition itself was not dismissed; instead, the bench expressly deferred any hearing on it. The review would be taken up only after the criminal contempt petition is disposed of.
The court's approach of converting the matter administratively, through a direction to the Registry, rather than issuing a show-cause notice within the review proceeding itself, reflects the seriousness with which the bench treated the written content. By directing registration as a separate criminal contempt petition, the bench ensured the matter would be placed before an appropriate bench for adjudication on the contempt aspect.
Outcome
The Registry was directed to register the matter as a criminal contempt petition and place it before the appropriate bench. The review petition — Civil Misc Review Application Defective No. 231 of 2026 — stands deferred and will not be heard until the criminal contempt petition is disposed of. The order was pronounced on 13 August 2026 by Chief Justice Arun Bhansali and Justice Kshitij Shailendra.