Mahipal Singh Rana v State of Uttar Pradesh

• The appellant advocate intimidated and threatened a Civil Judge (Senior Division) at Etah in open court on 16 Apr 2003 and 13 May 2003.
• The Allahabad High Court convicted him of criminal contempt (two months' simple imprisonment and Rs 2,000 fine) and asked the Bar Council of UP to act for misconduct.

1. Whether the conviction was justified.
2. Whether an advocate convicted of criminal contempt can continue to practise, and what the Court can do when the Bar Council does not act.

• The conviction was upheld. The prison sentence was set aside because of his age; the fine was upheld.
• S.24A applies at the post-enrolment stage as well. His enrolment stood suspended for two years under S.24A.
• Using its appellate power under S.38, the Court suspended his licence for a further five years (para 48).
• He stays debarred from appearing in any court in District Etah even after five years unless he purges the contempt as laid down in BCI v High Court of Kerala and R.K. Anand.
• If the Bar Council fails to act, the High Court can act under Art. 226; the Court also asked for a review of the regulatory framework.

Conviction for criminal contempt can carry professional consequences; S.24A is not confined to the enrolment stage, and courts may refuse audience until contempt is purged.