CASE BASED ASSIGNMENT

TOPIC In Re Prashant Bhushan vs Incorrect or That The on 31 August, 2020

Submitted to – Dr. Showkat Ahmad Wani Submitted by- Mansi Malik

Reg. NO. 11613623 Course Code – LAW 305

Roll No. A17 Course Name- Media & Law

ACKNOWLEDGEMENT

I owe a great many thanks to a great many people who helped and supported me during the
writing of this project. My deepest thanks to my Lecturer, Dr. Showkat Ahmad Wani for
guiding me and correcting various documents of mine with attention and care. He has taken
pain to go through the assignment and make necessary corrections as and when needed.
SCOPE AND OBJECTIVE OF THE STUDY

The object of the study is to” AMBIT OF CRIMINAL CONTEMPT IN RESPECT OF RE

PRASHANT BHUSHAN CASE” This study will also look into various other cases,

RESEARCH METHODOLOGY

The methodology adopted is largely descriptive. It has largely placed on secondary sources
like books and research papers. The lectures and classroom discussion have been rich with
valuable and gave directions to the research.

RESEARCH QUESTIONS

• To what amount Does the Fair Criticism amount to Contempt of Court Section 2(c)
• What are the consequences of Tweet in respect of Bar and the Bench
• Whether the priorities of supreme court are being misplaced
• Whether there must be an Independent Judicial Appointment Commission for
transparent functioning of the court
• To what extent the litigants are deprived of real access to justice in respect to Article
19(a) Freedom of Speech and Expression.
TABLE OF CONTENT

• EXECUTIVE SUMMARY
• STATEMENT OF FACTS
• ISSUES RAISED WITH RELATED CASE LAWS
• PHASES INVOLVED
• SUMMARY OF ARGUMENT
• OBITER DICTUM
• PROVISIONS LAID DOWN
• JUDGMENT
• AFFECTS OF THE JUDGMENT
• CONCLUSION
• OWN COMMENTS
• BIBLIOGRAPHY
NAME OF THE CASE

In Re Prashant Bhushan vs Incorrect or That The on 31 August, 2020

IN THE HON’BLE SUPREME COURT

NAME OF THE PARTIES

IN RE PRASHANT BHUSHAN ……………………………… PETITIONER

V.

SUO MOTO COGNIZANCE BY THE HON’BLE SUPREME COURT OF INDIA

DATE OF DECISION: 31 August, 2020

CORAM: A three- Judge Bench of Justice ARUN MISHRA, J. BR GAVAI AND J.

KRISHNA MURARI.
EXECUTIVE SUMMARY

This curious case based on the two tweets by Activist Lawyer Prashant Bhushan who himself
is aware about the functioning of the Judicial Accountability. Activist lawyer has made first
tweet on 27th June with regard to Role of four CJIs marking that the historians if would look
back will find that in last 6 years how the fur CJIs has degradation and destroying the
democracy even without formal emergency. And further tweeted on June 29th 2020 that How
the Chief Justice of India, SA Bobde rides a motorcycle amounting 50 lakhs, which belongs to
the BJP leader at Raj Bhavan Nagpur, without a mask and helmet at the time when he himself
has kept the whole citizens of India in Lockdown. And further this tweet led him a sup moto
cognizance of contempt of court Act 1971. which was led by three judge bench and held
Prashant Bhushan guilty for contempt of court section 3 marking that his tweets were based on
“distorted facts” it has further constituted a malicious attack on entire functioning of the
judiciary, and has also degrade the faith of citizens in respect of firmly functioning of the
judiciary. Thus the issues were raised in the whole media the fair criticism does not amount to
scandalising and lowering the dignity of the court and the Bench has given an opportunity to
Prashant Bhushan to Reconsider his statement however he refused to do so and had made guilty
under the Contempt of Court Act 1971 on 31august and ordered him to deposit Rs. 1/- ( as a
token of fine, A default of Fine would led him to Imprisonment of term three months or
debarred from practise further.

STATEMENT OF FACTS

• Heard Shri K.K. Venugopal, learned Attorney General for India, Dr. Rajeev Dhavan,
Shri Dushyant Dave, Shri C.U. Singh, learned senior counsel, and the contemnor Shri
Prashant Bhushan
• The contemnor, is a lawyer of 35 years of standing, who has pursued public interest
litigation successfully at some personal and professional cost. He got appreciation from
the Court. He is a founding member of Campaign for Judicial Accountability.
• And has looked into many cases of V. Ramaswamy case, Coal Mining case, Goa
Mining case, Orissa Mining case, an issue relating to the appointment of CVC, CBI
Director’s case, Lok Pal case.
 • The contemnor on June 27th and 29th has made two tweets in respect of Functioning of
the judiciary and on Chief Justice of India SA Bobde. stating that The Historians in
further look back in last 6 yrs. would find that how the 4 CJIs has degrade and destroyed
our democracy even without formal emergency.
• The contemnor also stated against CJI SA Bobde, Stating the nexus of judiciary and
executive. and tweeted that CJI rides a motorcycle amounting 50 lakhs which belongs
to a BJP leader at Raj Bhavan Nagpur, without a mask or helmet at a time when supreme
court has kept whole Country in lockdown.
• Bhushan’s Tweets Prima Facie Undermine Court1 : On 5th august 2020, the three-judge
bench J. Arun Mishra, BR Gavai and Krishna Murari had taken up Suo moto
cognizance and has further issued notice to contemnor and to Attorney General KK
Venugopal to assist the matter stating that the Bhushan tweets has undermine the
dignity and authority of the institution and offices of Chief Justice of India.
• And the Complaint also raised by senior advocate Harish Salve, informed the court that
an interview given by Bhushan to tehelka. had made allegations of corruption against
judges of the apex court. And Prashant Bhushan was made liable for criminal court for
scandalizing the court.

ISSUES RAISED

I. Whether the tweets were based on “distorted facts” which has constituted the
scurrilous/malicious attack upon entire judiciary
II. Whether Publication in good faith/ bona fide intention amounts to Contempt of
court Act 1971
III. Whether and to what extent the Fair criticism amounts to scandalous and
malicious attack upon Judiciary.

ISSUE NO 1 Whether the tweets were based on “distorted facts” which has constituted the
scurrilous/malicious attack upon entire judiciary2

1
The Quint, Vakasha Sachdev available at https://www.thequint.com/news/law/supreme-court-contempt-notice-
prashant-bhushan-twitter-27-29-june-cji-bike-4-cjis-tweets ( Last visited 06-09-202)
2
The ET( Economic times) https://economictimes.indiatimes.com/topic/Prashant-Bhushan-Bhushan (last visited
06-092020)
 • On 14th August 2020, the Bench made the contemnor guilty of criminal contempt
section 3 of the Act 1971for 2 tweets and said that it was purely based on “distorted
facts” and has constituted the malicious attack on the entire supreme court of India. and
has also affected the destabilising the very foundation of judiciary.
BENCH UNDERLINED THE IMPORTANCE OF PROTECTING THE FAITH OF
CITIZENS IN THE SUPREME COURT
• The defence taken cannot be said to be either in the public interest or bona fide one. On
the contrary, it is more derogatory to the reputation of this Court and would amount to
further scandalizing and bringing administration of justice in disrepute, in which the
common citizen of this country has faith and approaches this Court as a last resort for
getting justice.
• Registrar of the Orissa High Court v. Baradakanta Mishra and Ors3 The Hon’ble High
court held that “the Ignition of the contempt action should be substantial & malafide
interference with fearless Judicial action, not fair comment or trivial reflections on the
judicial process and personnel” This states that contempt action can only be initiate if
there is a substantial/ substance or mala-fide interference with fearless judicial action
amounts to contempt, but not fair comment.

ISSUE NO.2 Whether Publication in good faith/ bona fide intention amounts to Contempt
of court Act 1971

• Section 2 contempt of court act 1971, Act categorises contempt of court into two
Criminal contempt and Civil contempt. It involves Interfering in justice and
scandalizing and lowering the authority of court. Contempt of court has no were
expressly mentioned, it has been originated from England but the irony is that even a
single conviction for scandalising over 80 decades has taken place ever.
• Provisions in Articles 129 and 142(2) of the Constitution of India, cannot
override Article 19(1)(a) and 19(2) of the Constitution of India. Free Speech is a highly
valued right and is essential for democracy. In a \democracy, there is a right to dissent.
There is the freedom to build an opinion. Publication in good faith is suggested for the
Press, as defined in General Clauses Act in Section 3(22), it is a valid defence, if done
honestly, whether it is done negligently or not.

3
I.L.R. [1913] Cuttack, 134
 • IN A 2008 LECTURE BY JUSTICE MARKANDEY KATUJI Stated that “ If a person
says me a fool, whether inside and outside court, then I would have not seek any action
against the person because this hasn’t hamper or scandalizing the functioning/
administration of court, if it had so then he would have made the contemnor guilty
under Contempt of court act 1971.
• “After all words breaks no bones”
• On 18th August 2020, 1,500 Lawyers to Supreme Court4: Held that stoppage of
miscarriage of justice in Prashant Bhushan, if amount to guilty of Contempt Court5.

CONSTITUENT ASSEMBLY MEMBER PANDIT THAKUR DAS BHARGAVA

SAID “Power to reprimand contempt concerned only actions such as the disobedience
of an order or direction of court, which were already punishable infraction.” Speech in
criticism of the court, he argued, ought not to be considered as contumacious, for it
would simply open up the possibility of gross judicial abuse of such power. This means
only on that action contempt will be imposed which disobedience of any order if such
speech is not rebellious/contumacious this will amount judicial abuse on part of judges.

ISSUE NO.3 Whether and to what extent the Fair criticism amounts to scandalous
and malicious attack upon Judiciary

• ARTICE 19 FREEDOM OF SPEECH AND EXPRESSION UNDER FAIR

CRITICISM
• On 20th September supreme court gave back and forth discussion and gave time to
advocate Prashant Bhushan to re-consider the statement in contempt case and gave
unconditional apology. And quoted that on 24th August 2020. The contemnor refuses
to apologies to supreme court, and held that doing so will be ‘contempt of my
conscience6’.
• This tweet was based on fair criticism, Social and economic distress at an
unprecedented scale

4
The Indian Express, Apurva Vishwanath available at https://indianexpress.com/article/explained/supreme-
court-prashant-bhushan-contempt-case-6569845/ (last visited 06-09-2020)
5
The WIRE STAFF available at https://thewire.in/rights/prashant-bhushan-contempt-supreme-court-truth-
statement ( Last visited 06-09-2020)
6
The Live mint, Prathma Sharma available at https://www.livemint.com/news/india/sc-gives-prashant-
bhushan-3-days-to-reconsider-statement-in-contempt-case-11597912076332.html ( last visited at 06-09-202
 • Important judgment was adjourned by the Hon’ble supreme court and hence still in
such economic pandemic this tweet was found to be major issue in scandalizing the
court. Important judgment like7:-
• Challenge to Article 370 was uphold, Electoral Bond, Citizen Amendment Act, Habeas
Corpus Petition Article 32 was not even considered, Fundamental Rights of people of
Kashmir was not an important issue for such Hon’ble court hence this all tweets were
hence proved to be a fair criticism.

SUMMARY OF ARGUMENT

Argument alleged by Dr Rajeev Dhavan & Shri Dushyant Dave, learned senior counsel
appearing for the contemnor Shri Prashant Bhushan raised the following argument

• C. K. Daphtary & Ors. v. O. P. Gupta & Ors8 The Hon’ble Supreme Court held” that
of Contempt of Courts Act, 1971 which Section 13(b) was brought on statute book, so
as to allow truth as a defence” the court should exercise its jurisdiction with great
caution and care only in that case which are beyond reasonable doubt and held the
contemnor guilty for Contempt of court 1971.

GUIDELINES LAID DOWN ( IN RESPECT OF CRITICISM)

• In Re: S. Mulgaokar9 various guidelines have been laid down by this Court. They are,
free market of ideas, fair criticism in good faith when it is in the public interest, the
surrounding circumstances, the person who is making the comments, his knowledge in
the field regarding which the comments are made and the intended purpose will not
amount to contempt of court read with constitution of Indian in respect to Article 19(a).
• Section 13 of the Act enables the Court to permit justification by truth as a valid defence
in any contempt proceedings if it satisfied that such a defence is in the public interest
and the request for invoking the defence is bona fide. Reliance is placed
on Subramanian Swamy v. Arun Shourie10. In so far as the first tweet is concerned, the
tweet is an expression of opinion by Shri Prashant Bhushan that due to the Courts not
functioning physically the litigants are deprived of real access to justice. It is submitted
that this opinion also finds support from the observations made by this court In Re:

7
Ibid
8
AIR 1971 1 SCC 626,
9
AIR 1978 3 SCC 339
10
AIR 2014 12 SCC 344
 Financial aid for members of Bar affected by a pandemic that due to the suspension of
physical functioning of the Courts, the lawyers have been deprived of sources of
earning their livelihood
• With respect to the second tweet, this is again an expression of opinion by Shri Prashant
Bhushan. “It was submitted that this opinion has been shared by many others including
the retired judges of this Court. Reference was also made to the Press Conference held
on 12.01.2018 by the Sitting Judges of this Court. The role of the Supreme Court and
the last four Chief Justices”
• Provisions in Articles 129 and 142(2) of the Constitution of India, cannot
override Article 19(1)(a) and 19(2) of the Constitution of India. Free Speech is a highly
valued right and is essential for democracy. In a \democracy, there is a right to dissent.
There is the freedom to build an opinion. Publication in good faith is suggested for the
Press, as defined in General Clauses Act in Section 3(22), it is a valid defence, if done
honestly, whether it is done negligently or not.
• The opinions of the contemnor were bona fide and devoid of malice. Thus, the decision
with respect to the conviction is required to be recalled, and in such an event, no
sentence can be imposed.
• while applying the Principle of Proportionality the balance will have to tilt in favour of
the rights as against restrictions, inasmuch as the rights are fundamental in nature. The
opinions of the contemnor were bona fide and devoid of malice. Thus, the decision with
respect to the conviction is required to be recalled, and in such an event, no sentence
can be imposed.
• The tweets made by Shri Prashant Bhushan could be considered as bona fide criticism
in order to seek improvement in the functioning of the institution. He further stated, that
taking into consideration the causes represented by Shri Prashant Bhushan in various
public interest litigation and the service rendered by him to different classes of society
by bringing their issues to the notice of this Court.
• Free Speech is part of Article 19(1)(a) of the Constitution cannot be disputed. However,
we are not convinced that while exercising power under Article 129 of the Constitution,
we are interfering with the rights under Article 19(1)(a) of the Constitution.
• Supreme Court being a court of record can punish for contempt. He also argued about
the Freedom of Press, which is beyond doubt an important aspect of democracy. Free
 Speech is essential to democracy can also not be disputed, but it cannot denigrate one
of the institutions of the democracy.
• As observed in Maneka Gandhi v. Union of India and Another11, democracy is based
on free debate and open discussion, however, cannot go to the extent of the scurrilous
attack and shaking the faith of the general public in such institution. Freedom of speech
and expression includes the right to impart and receive information, which includes
freedom to hold an opinion as was held in Secretary, Ministry of Information and
Broadcasting, Government of India & Ors. v. Cricket Association of Bengal & Ors.,12.
No doubt, one is free to form an opinion and make fair criticism but if such an opinion
is scandalous and malicious, the public expression of the same would also be at the risk
of the contempt jurisdiction.

• The lawyers are supposed to be fearlessly independent and robust but at the same time
respectful to the institution.
• Dr. Dhavan, learned senior counsel, also argued that as per Section 3(22) of the General
Clauses Act, things shall be considered to be done in good faith, in fact, if done
honestly, whether it is done negligently or not.

ARGUMENT OF 24TH JUNE 2020 REFUSE TO APOLOGISE

• Dr. Dhavan, learned senior counsel, fairly stated that I find it hard to believe that
the Court finds my tweet "has the effect of destabilizing the very foundation of this
important pillar of Indian democracy". I can only reiterate that these two tweets
represented my bonafide beliefs, the expression of which must be permissible in any
democracy
• I believe that open criticism of any institution is necessary in a democracy, to safeguard
the constitutional order. We are living through that moment in our history when higher
principles must trump routine obligations, when saving the constitutional order must
come before personal and professional niceties,
• My tweets were nothing but a small attempt to discharge what I considered to be my
highest duty at this juncture in the history of our republic

11
AIR 1978 1 SCC 248
12
AIR 1995 2 SCC 161
 RECONSIDER APOLOGY ON 20TH AUGUST 2020

• I did not tweet in a fit of absence mindedness It would be insincere and contemptuous
on my part to offer an apology for the tweets that expressed what was and continues
to be my bonafide belief. Therefore, I can only humbly paraphrase what the father of
the nation Mahatma Gandhi had said in his trial I do not ask for mercy. I do not appeal
to magnanimity. I am here, therefore, to cheerfully submit to any penalty that can
lawfully be inflicted upon me for what the Court has determined to be an offence, and
what appears to me to be the highest duty of a citizen.”
• The supplementary statement has been made by Shri Prashant Bhushan on 24.08.2020
to the following effect: “It is with deep regret that I read the order of this Hon’ble
Court dated 20th of August. At the hearing the court asked me to take 23 days to
reconsider the statement I made in the court.13 However, the order subsequently states:
“We have given time to the contemnor to submit unconditional apology, if he so
desires.” I have never stood on ceremony when it comes to offering an apology for
any mistake or wrongdoing on my part. It has been a privilege for me to have served
this institution and bring several important public interests causes before it. I live with
the realisation that I have received from this institution much more than I have had the
opportunity to give it. I cannot but have the highest regard for the institution of the
Supreme Court.
• Therefore, I express myself in good faith, not to malign the Supreme Court or any
particular Chief Justice, but to offer constructive criticism so that the court can arrest
any drift away from its longstanding role as a guardian of the Constitution and
custodian of people’s rights.
• Therefore, an apology for expression of these beliefs, conditional or unconditional,
would be insincere. An apology cannot be mere incantation and any apology has to,
as the court has itself put it, be sincerely made. This is specially so when I have made
the statements bonafide and pleaded truths with full details, which have not been dealt
with by the Court.

13
Indian Express, Opicit at pg.125
 OBITER DICTUM

Observation made by the Hon’ble Supreme court in respect of Tweet, 27th June

• The Hon’ble Supreme Court observed that there is no reason as to why he should not
express regret in the present proceedings also. He stated that the same could be
considered as regret in the present proceedings also.
• Unless the contemnor withdraws the said statements, in view of the provisions
of Section 13(b) of the Act, the statements cannot be taken off.
• The Learned Attorney General was fair enough to state that insistence on the part of the
contemnor to press into service various objectionable statements made in the pleading
was not warranted and also not justifiable. He fairly stated that in the interest of the
administration of justice, the contemnor ought not to have made such statements
Observation made by the Hon’ble Supreme court in respect of Tweet, 29th June
• We are of the view that, in the circumstances, the defence taken cannot be said to be
either in the public interest or bona fide one. On the contrary, it is more derogatory to
the reputation of this Court and would amount to further scandalizing and bringing
administration of justice in disrepute, in which the common citizen of this country has
faith and approaches this Court as a last resort for getting justice.
• He has further averred with respect to the withdrawal of the case which was filed
questioning the decision of rejection of impeachment motion moved against the then
Chief Justice. He has also referred to various matters pending adjudication before this
Court and also adversely commented on the functioning of this Court. He has raised
eyebrows on the Ayodhya verdict and blamed this Court.
• Though a fair criticism of judgment is permissible in law, a person cannot exceed the
right under Article 19(1)(a) of the Constitution to scandalize the institution.
• Hostile criticism of the judges or judiciary is definitely an act of scandalizing the Court.
Defamatory publication concerning the Judge or institution brings impediment to
justice14.
• In C. Ravichandran Iyer v. Justice A.M. Bhattacharjee and Others15 It was also
observed that fair criticism is based on the authentic and acceptable material

14
7TH (In Halsbury’s Laws of England, (Ed.), Fourth Edition, Volume 9, in para 27,)
15
AIR(1995) 5 SCC 457,)
 permissible but when criticism tends to create apprehension in the minds of the
people regarding integrity, ability and fairness of the Judge, it amounts to
contempt. Such criticism is not protected under Article 19(1)(a) of the
Constitution. It was also observed that the Judge should maintain high standard of
conduct based on high tradition.
• “The purity of the Bench depends upon the purity of the Bar. The integrity of the
judiciary is the safeguard of the nation, but the character of the Judges is practically but
the character of the lawyers. Like begets like”

Judicial Individualism

“Whether judiciary must be free from not only executive pressure but also from other
pressure, individual judge has to feel secure in view of social demand for active
judicial role which is required to be fulfilled”.
In consequence, the court has regarded with particular seriousness allegations of
partiality or bias on the part of a Judge or a court. Criticism of a Judge’s conduct or
of the conduct of a court even if strongly worded16, is, however, not contempt,
provided that the criticism is fair.
• In Indirect Tax Practitioners’ Association v. R.K. Jain17, if a speech or article,
editorial, etc. contains something which appears to be contemptuous and this
Court or the High Court is called upon to initiate proceedings under the Act and
Articles 129 and 215 of the Constitution, the truth should ordinarily be allowed as
a defence unless the Court finds that it is only a camouflage to escape the
consequences of deliberate or malicious attempt to scandalise the court or is an
interference with the administration of justice.
Freedom of expression and duty of Advocate
• The Court must, therefore, harmonise constitutional values of free criticism and the
need for a fearless curial process and its presiding functionary, the Judge. If freedom of

16
In Halsbury’s Laws of England (4th Edn.) Vol. 9, para 27, at p. 21,
17
AIR (2010) 8 SCC 281
 expression subserves public interest in reasonable measure, public justice cannot gag
it.
• but if the court considered the attack on the Judge or Judges scurrilous, offensive,
intimidatory or malicious, beyond condonable limits, the strong arm of the law must
strike a blow on him who challenges the supremacy of the rule of the law by fouling its
source and stream.

PROVISIONS LAID DOWN

• Section 2 of the Contempt of Courts Act, 1971 for to scandalise or lowers the authority
of any court,

JUDGEMENT
• It was the wake-up call for scandalizing the functioning of court through its distant fact
which were scurrilous/malicious attack on the entire supreme court.
• The contemnor not only gave wide publicity to the second statement submitted
before this Court on 24.08.2020 prior to the same being tendered to the Court, but
also gave various interviews with regard to sub judice matter, thereby further
attempting to bring down the reputation of this Court. If we do not take cognizance
of such conduct it will give a wrong message to the lawyers and litigants
throughout the country.

• However, by showing magnanimity, instead of imposing any severe punishment,

we are sentencing the contemnor with a nominal fine of Re.1/ (Rupee one).

• therefore, the Hon’ble Bench of the supreme court, on 31st august 2020 sentence the
contemnor with a fine or Re.118/ (Rupee one) to be deposited with the Registry of
this Court by 15.09.2020, failing which he shall undergo a simple imprisonment for
a period of three months and further be debarred from practising in this Court for a

18
Available at https://indiankanoon.org/doc/196421935/( last visited 06-09-2020)
 period of three years. Accordingly,19 the present proceedings including all pending
applications, if any, shall stand disposed of herewith.

AFFECTS OF THE JUDGMENT

• The reactions to the sentencing span a range of opinions, given that the case has
polarised Indians on and off social media.
• While some have welcomed the fine as a necessary punishment, others said that it is ,
in fact, a win for Mr. Bhushan who faced the prospect of jail time.

CONCLUSION

• India should come up with notional campaign for judicial accountability to serve full
time Independent appointment commission so there must be a collegium system and no
hinderance of nepotism, and arbitrariness and free flow of transparency.
• Judiciary must be free form not only the executive pressure but also from other pressure.
Individual judge has to feel secure in view of social demand for active judicial role
which requires to be fulfilled.

OWN COMMENTS
• The tweets were not at all based on “distorted facts” which has constituted,
scurrilous/malicious attack upon entire judiciary, the fair criticism and bringing the
reality to the public does not amount to scandalizing the administration of functioning
of the entire supreme court.
• When the pandemic has set off social and economic distress at an unprecedented scale,
when crucial constitutional cases have continued to drag on for years.
• Power to reprimand contempt concerned only actions such as the disobedience or
contumacious speech against regulation of judiciary amount to contempt of court but
however in such case, the speech was all based on Fair criticism.

19
Live Mint, Japnam Bindra available at https://flipboard.com/@flip_india/the-daily-edition-india-
9cetuivhz/sc-fines-prashant-bhushan-one-rupee-in-contempt-case/a--
lsJ1TgTS_i_IBQBYHuQrg%3Aa%3A106586776-40b8e03b6a%2Flivemint.com ( Last visited on06-092020)
 BIBLIOGRAPHY
website

1. The Quint, Vakasha Sachdev available at

https://www.thequint.com/news/law/supreme-court-contempt-notice-prashant-
bhushan-twitter-27-29-june-cji-bike-4-cjis-tweets ( Last visited 06-09-202)

2. The ET( Economic times) https://economictimes.indiatimes.com/topic/Prashant-

Bhushan-Bhushan (last visited 06-092020)
3. The Indian Express, Apurva Vishwanath available at
https://indianexpress.com/article/explained/supreme-court-prashant-bhushan-
contempt-case-6569845/ (last visited 06-09-2020)
4. The WIRE STAFF available at https://thewire.in/rights/prashant-bhushan-contempt-
supreme-court-truth-statement ( Last visited 06-09-2020)