ADVOCATE GENERAL, STATE OF BIHAR vs MADHYA PRADESH KHAIR INDUSTRIES LTD.

The Supreme Court held that abuse of the court process that hampers judicial proceedings constitutes contempt under Section 2(C) of the Contempt of Courts Act, 1971. The Court found that the respondents' repeated applications obstructed justice, thus justifying contempt proceedings despite the High Court's dismissal based on limitation under Section 20. The appeal was allowed, emphasizing that contempt can arise from conduct that undermines public interest in judicial administration.