THAKUR JUGAL KISHORE SINHA vs SITAMARHI CENTRAL CO-OPERATIVE BANK LTD. & ANR.

The Supreme Court held that the Assistant Registrar of Co-operative Societies, while adjudicating disputes under Section 48 of the Bihar and Orissa Co-operative Societies Act, 1935, functions as a court for the purposes of the Contempt of Courts Act, 1952. The Court ruled that the Assistant Registrar is subordinate to the High Court under Section 3 of the Contempt of Courts Act, and the appellant's statements constituted contempt. The conviction of the appellant was upheld, emphasizing the necessity of respect for all courts regardless of their hierarchy.