Case Details

Citation(s)
2025 SLG 5387 2025 SLD 5387 = 2025 LHC 7857
Lahore High Court
Criminal Revision No. 8188 of 2021,
PRESENT; (Tanveer Ahmad Sheikh) Judge
Date of hearing. 13.11.2025. Appellant by:- Ch. Ahsan Gujjar, Advocate with petitioner Dr. Faheem Ikram Butt.
Respondent (State) by Hammad Iftikhar Syed and Rao Atif Khan, Deputy District Public Prosecutors.

(Dr. Faheem Ikram Butt

VS

. The State)

Law: Pakistan Penal Code (PPC),1860

Section: 228

Law: Code of Criminal Procedure, 1898

Section: 480, 476, 482, 260–265

Summary

The criminal revision petition challenged the conviction and sentence of the petitioner under section 228, PPC for allegedly causing insult and disturbance in court. The trial court summarily convicted the petitioner under section 480, Cr.P.C. and sentenced him to three days’ imprisonment along with a fine of Rs.1,500/-, which was upheld in appeal. The High Court held that while a court is empowered to act summarily for contempt committed in its presence, section 480, Cr.P.C. strictly limits the punishment that can be imposed. Since the trial court exceeded its jurisdiction by awarding a sentence beyond the statutory limit without adopting the procedure under section 476, Cr.P.C., the conviction and sentence were illegal. Consequently, the revision was accepted and the impugned judgments were set aside.

Tag Line

Summary contempt jurisdiction under section 480, Cr.P.C. is limited—Sentence beyond statutory limit is illegal and void.

ORDER; 

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