This article is a comment on the EMS Namboodiripad v. T N Nambiar case (ref. ), which also discusses the evolution of the Indian law of Contempt, the influence of the English law on it, and suggests that the power of the courts under ‘contempt’ should be redefined in the context of ‘reasonableness’, and says that the dicta of the chief justice insofar as it restricts the restriction on freedom of expression only to cases where contempt is ‘manifest’ or ‘substantial’ is a definite improvement. It notes that the law of contempt is necessary, but should be redefined and limited to cases where it actually interferes with the administration of justice.
Sathe, S. P. "Freedom of Speech and Contempt of Court." Economic and Political Weekly 5, no. 42 (1970): 1741-742. http://www.jstor.org/stable/4360620