BRAJNANDAN SINHA vs JYOTI NARAIN.

The Supreme Court held that a Commissioner appointed under the Public Servants (Inquiries) Act, 1850 is not a court within the meaning of the Contempt of Courts Act, 1952. The Court clarified that the definition of 'court' does not extend to such Commissioners, thereby affirming the legal distinction between administrative inquiries and judicial proceedings. Consequently, the appeal was dismissed, and the order of the Patna High Court was upheld.