Delhi High Court Holds YouTuber Guilty Of Criminal Contempt For Scandalous Remarks

While taking a very stern view of scandalous remarks made about the judiciary without having any valid proof, the Delhi High Court, in a most learned, laudable, landmark, logical and latest judgement titled 'Court On Its Own Motion Vs Shiv Narayan Sharma Adv and Ors' in CONT.CAS.(CRL) 3/2025 & CRL.M.A. 1909/2026, CRL.M.A. 2184/2026, CRL.M.A. 5815/2026, CRL.M.A. 9152/2026 and cited in Neutral Citation No.: 2026:DHC:3275-DB that was reserved on 6.4.2026 and then finally pronounced on 21.04.2026, has held YouTuber Gulshan Pahuja guilty of criminal contempt of court for making scandalous comments about the judiciary, including baseless allegations of bias against judicial officers in his videos.

Division Bench Observations On Judicial Integrity

It must be underscored that the Division Bench comprising the Hon’ble Mr Justice Navin Chawla and the Hon'ble Mr Justice Ravinder Dudeja underscored that allegations against the integrity of a judicial officer cannot be made lightly.

Controversial YouTube Content Details

• The controversial videos were uploaded by Gulshan Pahuja
• Platform: YouTube
• Channel Name: “Fight 4 Judicial Reforms”
• Content Included: Allegations of bias against judicial officers

Court Findings And Conclusion

We thus see that the Delhi High Court concluded very clearly that Pahuja’s conduct was unpardonable and warranted strict action. Therefore, the Court held Pahuja guilty of criminal contempt of court.

Next Hearing And Punishment Stage

The court is yet to deliver a verdict on punishment. It has sought Pahuja’s response on this aspect within two weeks. The Division Bench has also directed Pahuja to be personally present on the next day of hearing on May 12.

At the very outset, this brief, brilliant, bold and balanced judgment authored by Hon’ble Mr Justice Navin Chawla for a Division Bench of the Delhi High Court comprising of himself and Hon’ble Mr Justice Ravinder Dudeja sets the ball in motion by first and foremost putting forth in para 1 that,

“These Contempt Petitions have been registered on the reference dated 15.01.2025 addressed by Ms. Charu Asiwal, the learned ACJ/CCJ-ACR, Shahdara, Karkardooma Courts, Delhi; and the reference dated 10.03.2025 addressed by Mr. Ajay Singh Parihar, the learned ACJ-CCJ-ARC, North, Rohini Courts, respectively, making complaints regarding contentious videos and banners (dated 29.10.2024 and 05.01.2025 as far as Contempt Case (Crl) 3/2025 is concerned, and dated 03.03.2025 and 07.03.2025 as far as Contempt Case (Crl) 4/2025 is concerned) uploaded by Mr. Gulshan Pahuja, who is the respondent no.2 in both of these petitions, on his YouTube channel “Fight 4 Judicial Reforms”.”

Division Bench Observations

Para 2: YouTube Video Context

As we see, the Division Bench then observes in para. 2 that,

“In the YouTube video uploaded on 29.10.2024, the respondent no. 2 interviews Mr.Shiv Narayan Sharma, Advocate (respondent no.1 in the said contempt case), and the introduction itself gives the tenor of the interview.”

Para 3: Purpose of the Interview

Truth be told, the Division Bench then lays bare in para. 3 that,

“The interview is primarily aimed towards a demand for having audio-video recordings of the Court proceedings in general and discusses two cases which had been allegedly dealt with by the above named judicial officers.”

Para 4: Remarks and Apology by Respondent No. 1

To put things in perspective, the Division Bench envisages in para. 4 that,

“The respondent no.1, Mr. Shiv Narayan Sharma, in the course of the interview, details his alleged experience in two cases; one before the Court of Ms. Charu Asiwal and the other before the Court of Mr. Ajay Narwal. In the course of the interview, however, respondent no. 1 makes some objectionable and derogatory remarks against the judicial officers and the judicial institution as a whole. We are not giving complete details of the same as respondent no. 1, Mr. Shiv Narayan Sharma, has filed a reply dated 19.08.2025, tendering his unconditional and unqualified apology for the same. He has also appeared in person before us and has reiterated his apology with an undertaking not to make such scandalous and derogatory remarks in future. We find the apology to be genuine and, therefore, accept the same. For the said reason, we drop the proceedings and discharge respondent no. 1, Mr. Shiv Narayan Sharma in Cont. Cas. (Crl.) 3/2025.”

Para 5: Proceedings Against Respondent No. 2

As it turned out, the Division Bench enunciates in para. 5 that,

“The respondent no. 2, however, has continued to justify his actions and, therefore, we shall be proceeding with further consideration of the two Contempt Cases against him.”

Legal Clarifications on Contempt Jurisdiction

Para 9: Freedom of Expression vs Contempt

Do note, the Division Bench notes in para. 9 that,

“At the outset, we would note and clarify that as far as the campaign launched by the respondent no. 2 for having audio-visual recording of the court proceedings is concerned, there can be no objection, certainly not in contempt jurisdiction, as this is his campaign on an issue which he believes will bring about a reform in the justice dispensation system. We must at the very outset emphasize that contempt jurisdiction is not to be exercised nor is being exercised herein for, in any manner, opposing the said campaign. Every person is entitled to hold an opinion, and to express it, on the manner in which the justice dispensation system can be improved. However, in our view, naming of the two specific judicial officers and the manner of doing so in the banner, is not intended to promote the said campaign of having audio-video recording of the court proceedings, but to create sensationalism and distrust against the two named judicial officers, thereby lowering their authority.”

Second Video Analysis

Para 11: Apology by Mr Deepak Singh

Do also note, the Bench then notes in para 11 that,

“The video contains an interview of the respondent no.1 in the said case, that is, Mr.Deepak Singh, wherein he narrates the alleged proceedings of a case before the Court of Mr.Ajay Singh Parihar, who was holding the Electricity Court. It also contains certain derogatory and contentious remarks made by the respondent no.1, Mr. Deepak Singh, against the Court. However, respondent no. 1, Mr. Deepak Singh, has also filed a reply dated 19.08.2025, tendering an unconditional and unqualified apology to the Court. He has also appeared in person and reiterated his apology, which the Court finds to be genuine. He has undertaken to the Court that he will not repeat such actions of making scandalous remarks against any judicial officer or the judicial institution in future. For the said reason, we drop the proceedings and discharge respondent no. 1, Mr. Deepak Singh, in this regard.”

Key Takeaways Summary

• Contempt petitions arose from controversial YouTube videos and banners.
• Courts accepted unconditional apologies from Respondent No. 1 in both instances.
• Proceedings continue against Respondent No. 2.
• Freedom of expression is protected, but not at the cost of judicial dignity.
• Targeting specific judges to create distrust may amount to contempt.

Case Summary Table

Criminal Contempt and Judicial Criticism – Division Bench Analysis

Fair Criticism vs Contempt of Court

Most rationally, the Division Bench points out in para 49 that:

“The general comments of the respondent no. 2 on the ills of the judicial system as a whole, would also not have persuaded us to proceed against him in exercise of our contempt jurisdiction and we would have let it pass, may be as a fair criticism or as a venting of anger by a person who feels that he did not get the justice he deserved or felt that the same was delayed.

We must remember that one or the other party may leave disgruntled with the order passed by the Court and may some time vent out his/her frustration by making uncharitable remarks; these are to be taken in our stride and not in an oversensitive manner.

However, in the present case, the respondent no. 2 has not confined himself to this debate nor is his venting out frustration aimed to be a fair criticism.

He has personally attacked three Judicial Officers and even imputed that in case a litigant’s case is listed before them, such litigant should not expect justice.

What is the foundation of such over-sweeping remarks against the Judicial Officers?

Even upon our repeated queries, the respondent no. 2 justifies these sweeping statements only on basis of the interviews given by the respondent no. 1 in these contempt references.

To a query if the respondent no. 2 had even got the facts of these cases talked about in the interviews verified from the judicial record, the answer is in the negative from the respondent no. 2.

While the interviews given by respondent No. 1 were on the premise that if the proceedings of those cases were being recorded, the outcome may have been different, the respondent no. 2 twisted the same to a narration that these Judicial Officers themselves were not dispensing justice and any litigant before them should not expect so.

The intent of respondent no. 2 is, therefore, writ large of only scandalising and lowering the image of these Judicial Officers in the general public, thereby lowering the authority of the Court.

It is not to generate a healthy debate but to scandalize the Court. It is not bona fide but is mala fide to bring to disrepute the judicial system and to lower the authority of the courts.”

Key Observations from Paragraph 49

• General criticism of the judiciary may be tolerated as fair comment.
• Courts acknowledge emotional reactions from dissatisfied litigants.
• Personal attacks on judicial officers cross the line into contempt.
• Unverified allegations weaken credibility and legal standing.
• Twisting facts to malign judges amounts to scandalising the court.

Cornerstone of the Judgment – Paragraph 50

Most significantly and so also most forthrightly, the Division Bench encapsulates in para 50 what constitutes the cornerstone of this notable judgement, postulating precisely that:

“If one has to attack a Judicial Officer on his integrity or competence, it must be done with cogent evidence; it cannot be made lightly.

We must remember that such an attack, if made without any basis, undermines the authority of the Judicial Officer and interferes with dispensation of justice by him/her without fear or favour.

Any such criticism must therefore be well founded, specially because the Judicial Officer, unlike the complainant, has no means to justify his actions in public.

When a Judicial Officer dispenses justice, he/she is bound to make mistakes; no judicial officer is or can be expected to be 100% correct all the time; it is for this reason that we have a hierarchy of courts, where a litigant can approach the higher court if he/she is dissatisfied by the verdict.

In such remedy, may be the order is set aside, however, this also does not mean that the judicial officer passing the original order did not act with integrity or was incompetent.

In the present case, even this stage had not reached.

The respondent no. 2 pronounced his verdict against the concerned Judicial Officers without any basis and thereby undermined their authority.

This is a classic case of criminal contempt being committed by him.”

Key Legal Principles from Paragraph 50

• Allegations against judges must be backed by cogent evidence.
• Baseless attacks interfere with judicial independence.
• Judges cannot publicly defend themselves, requiring higher responsibility from critics.
• An error in judgement does not imply lack of integrity or competence.
• Judicial hierarchy exists to correct errors—not public accusations.
• Premature and unfounded conclusions can amount to criminal contempt.

Summary Table: Legal Takeaways

Conclusion: When Criticism Becomes Criminal Contempt

This judgement clearly draws the line between fair criticism and criminal contempt. While the judiciary remains open to scrutiny, any attempt to scandalise the court or undermine judicial authority without evidence is treated as a serious offence under contempt law.

Division Bench Findings on Criminal Contempt

Equally significant is that the Division Bench then propounds in para 51 holding that

“In Cont. Cas (Crl.) 4/2025, the banner and the introduction to the YouTube video uploaded by the respondent No. 2 on 07.03.2025, though aimed at the Supreme Court, is in effect to lower the dignity of the judicial system as a whole. It is not just the use of the derogatory term against the Supreme Court, but against the entire judicial system. It is intended to mock the system, bringing it to disrepute and to lower its dignity and authority. It is not the criticism of the orders/judgments passed by the Supreme Court, but of the judicial system as a whole. To our view, it is a criminal contempt of the Court, which is unpardonable and for which strict action is required to be taken against the respondent no. 2.”

Rejection Of Bona Fide Defense (Para 52)

Be it noted, the Division Bench notes in para. 52 that:

“The plea of the respondent no. 2 that the respondent no.2 was acting bona fide or had no intention to lower the dignity of the Court, cannot be accepted. The acts attributed to the respondent no.2 speak for themselves and it is a case of res ipsa loquitur. There can be no justification for the same. It is certainly not protected under Article 19(1)(a) of the Constitution of India.”

• Key takeaway: Intent is irrelevant when the act itself lowers judicial dignity.
• Legal principle applied: Res ipsa loquitur (the act speaks for itself).
• Constitutional limit: Not protected under Article 19(1)(a).

Clarity Of Charges Against Respondent (Para. 53)

It is also worth noting that the Division Bench notes in para. 53 that:

“The submission of the respondent no. 2 that the Charges framed against him do not specify the allegation on which he has been proceeded against, does not hold any water. The Charges are clear and specific and from the reply of the respondent no. 2, it is quite evident that he understands the same fully.”

• Court observation: Charges are precise and understandable.
• Conclusion: No ambiguity in allegations.

Finding Of Guilt For Criminal Contempt (Para. 54)

As a corollary, the Division Bench then directs and holds in para. 54 that:

“We, therefore, find the respondent no. 2 guilty of having committed criminal contempt of Court as defined in Section 2(c) of the Contempt of Courts Act, 1971.”

Opportunity To Be Heard On Punishment (Para 55)

It would be instructive to note that the Division Bench hastens to add in para 55, noting that:

“To give him an opportunity to make submissions on the punishment to be awarded to him under Section 12 of the Act, we give him notice for the same under Rule 13(1) of the Contempt of Courts (Delhi High Court) Rules, 2025. He may file his submissions on punishment within a period of two weeks.”

• Right given: Opportunity to argue on punishment
• Time limit: Two weeks
• Relevant law: Section 12 of the Act

Acceptance Of Apology And Discharge (Para. 56)

For clarity, the Division Bench clarifies in para. 56, stating that:

“As we have accepted the apology tendered by the respondent nos.1 in the two references, that is, Mr.Shiv Narayan Sharma and Mr.Deepak Singh, they are discharged from their respective contempt cases.”

• Respondents discharged: Due to accepted apology
• Names: Mr Shiv Narayan Sharma and Mr Deepak Singh

Next Hearing Date And Personal Appearance (Para 57)

It would be worthwhile to note that the Division Bench notes in para. 57 that:

“List on 12th May, 2026, when the respondent no. 2 shall remain personally present.”

Direction For Hindi Translation (Para 58)

Further, the Division Bench then directs and holds in para 58 that

“A copy of this judgment, translated into Hindi, be supplied by the Registry to the respondent no.2.”

Final Direction For Certified Copy (Para 59)

Finally, the Division Bench then concludes by directing and holding in para. 59 that:

“A copy of this judgment be given dasti under the signatures of the Court Master.”

Sanjeev Sirohi, Advocate,
 s/o Col (Retd) BPS Sirohi, A - 82, Defence Enclave,
 Sardhana Road, Kankerkhera, Meerut – 250001, Uttar Pradesh.