J. K. Gupta vs D.G. Investigation & Registration & Ors

The Supreme Court addressed the issue of whether the Chairman of the Monopolies and Restrictive Trade Practices Commission had the authority to adjudicate a case of criminal contempt under Section 12 of the Contempt of Courts Act, 1971. The Court held that the contempt proceedings must be conducted by a Bench of at least two members as mandated by Section 18 of the Act, thus overturning the conviction of the appellant. The judgment emphasized the necessity of adhering to procedural requirements in contempt cases to ensure fair adjudication.