The Supreme Court, while setting aside a High Court order that sought to revoke a medical practice license due to contempt of court, explicitly pointed out that such a decision was not in accordance with the Contempt of Courts Act. Justices BR Gavai and Sanjay Karol, on the bench, clarified that the Contempt of Courts Act of 1971 does not authorize courts to revoke medical licenses.
The Supreme Court concluded that the punishment imposed on the offender was entirely inconsistent with the statute and therefore invalid. The Court emphasized that the Contempt of Courts Act clearly delineates the penalties that can be imposed for contemptuous behavior, and deviating from these provisions is not permissible.
The Court further underscored that only the National Medical Commission holds the authority to take action against medical practitioners, including revoking their licenses, for any misconduct. As a result, the Supreme Court reversed a previous Calcutta High Court order from July 2022, which suspended a doctor’s medical license for two years due to his failure to demolish an unauthorized structure.
The Supreme Court clarified that the National Medical Commission Act of 2019 exclusively governs the issuance, regulation, and suspension of medical practice licenses. Any disciplinary action against licensed physicians for “misconduct” is solely within the purview of the body established by this Act. The Act provides a comprehensive and exhaustive mechanism to revoke a registered practitioner’s license for professional misconduct, subject to an investigation and adherence to the audi alterum partem principles.
The Court distinguished between contempt of court and professional malfeasance by medical practitioners, stating that they are separate offenses. While contempt of court is dealt with under the Contempt of Courts Act, professional misconduct falls under the jurisdiction of the National Medical Commission Act of 2019.
The Court also highlighted that Section 12(1) of the Contempt of Courts Act only prescribes a maximum punishment of six months of simple imprisonment or a fine of ₹2,000 for contempt of court. Furthermore, subsection 2 of this provision explicitly states that no other punishment can be imposed on a person convicted of contempt of court.
During the proceedings, the Court was informed that the necessary demolition had been carried out. Consequently, the Court allowed the appeal and clarified that the physician’s license would be reinstated.
