MOHD. IKRAM HUSSAIN vs STATE OF U.P. & OTHERS

The Supreme Court upheld the High Court's order committing the appellant for contempt under Article 226 of the Constitution and Section 491 of the Code of Criminal Procedure, 1898, due to willful disobedience in producing Kaniz Fatima, the alleged wife, for a habeas corpus petition. The Court clarified that a writ of habeas corpus can be issued not only against the State but also for private detention, emphasizing that such writs are rare in cases involving husbands seeking custody of their wives. The Court concluded that the High Court acted within its jurisdiction and the contempt order was justified due to the appellant's failure to comply with the court's directive.