Delhi High Court Holds YouTuber Gulshan Pahuja Guilty Of Criminal Contempt Of Court (2026)

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. 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. The controversial videos were uploaded by Gulshan Pahuja on his YouTube channel “Fight 4 Judicial Reforms”.

Court Observations On Contempt And Conduct

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. 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.

Background Of The Case And Judicial Bench

At the very outset, this brief, brilliant, bold and balanced judgement authored by Hon’ble Mr Justice Navin Chawla for a Division Bench of the Delhi High Court comprising 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.'"

YouTube Video And Interview 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.”

Focus Of Interview And Allegations

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.”

Court Analysis And Apology Acceptance

To put things in perspective, the Division Bench envisages in paragraph 4 that Mr Shiv 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.”

Key Highlights Summary

• Delhi High Court held Gulshan Pahuja guilty of criminal contempt of court.
• The case involves scandalous and unverified allegations against judicial officers.
• The court emphasised that judicial integrity cannot be questioned without proof.
• Punishment is yet to be decided; response sought within two weeks.
• Personal appearance of Pahuja directed on the next hearing date (May 12).
• Apology of Advocate Shiv Narayan Sharma accepted; proceedings against him dropped.

Case Details At A Glance

Contempt Of Court Judgment Analysis

Division Bench Initial Observation (Para 5)

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.”

Campaign And Free Speech Clarification (Para 9)

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 emphasise the following:

• Contempt jurisdiction is not being exercised to oppose the campaign
• Every person has the right to hold and express opinions
• Reforms in the justice system are open to public debate

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.”

Video Content And Apology Consideration (Para 11)

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.

Key observations from the Court:

• Derogatory and contentious remarks were made
• An unconditional and unqualified apology was submitted
• The respondent appeared in person and reiterated the apology
• The Court found the apology 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.”

Judicial Tolerance And Fair Criticism (Para 49)

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.”

Court Perspective On Public Reaction

• Litigants may leave court dissatisfied
• Frustration may lead to uncharitable remarks
• Courts should not react in an oversensitive manner

Limits Of Acceptable Criticism

However, the Court draws a clear distinction:

• Fair criticism is acceptable
• Personal attacks on judicial officers are not
• Unverified allegations undermine judicial authority

“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.”

Key Findings Against Respondent No. 2

Final Judicial Conclusion

“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.”

Criminal Contempt of Court: Judicial Integrity And Legal Boundaries

Cornerstone Observations (Para 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, especially 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 a remedy, maybe 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 been reached. 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.”

YouTube Content And Judicial Dignity (Para. 51)

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, are 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 into disrepute and lowering its dignity and authority. It is not the criticism of the orders/judgements passed by the Supreme Court but of the judicial system as a whole. In 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 Defence (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.”

Clarity Of Charges (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.”

Finding Of Guilt (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 Address Punishment (Para 55)

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

“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.”

Discharge Of Other Respondents (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.”

Next Hearing And Personal Appearance (Para 57)

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

• The matter is listed on 12th May, 2026
• The respondent no. 2 shall remain personally present

“The list on 12th May, 2026, when the respondent no. 2 shall remain personally present. The list is present."

Direction For Hindi Translation (Para 58)

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

"A present copy of this judgement, translated into Hindi, be supplied by the Registry to the respondent no. 2."

Certified Copy Direction (Para 59)

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

"A copy of this judgement be given dasti under the signatures of the Court Master.”

Key Legal Takeaways

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