Compare the contempt jurisdiction of India's Supreme Court under Article 129 with similar provisions in other South Asian democracies.

Article 129 declares the Supreme Court "a court of record" possessing "all the powers of such a court including the power to punish for contempt of itself" [1]. South Asia's constitutions share this common-law inheritance, but diverge sharply in how contempt is defined, codified and actually enforced against the executive.

Common constitutional design

• India: Article 129 for the Supreme Court, mirrored by Article 215 for High Courts [1].
• Bangladesh: Article 108 repeats the Indian formula almost verbatim, but makes the power to order investigation or punishment expressly "subject to law" — a wider legislative check than India's [4].
• Sri Lanka: Article 105(3) makes the Supreme Court and Court of Appeal superior courts of record, expressly authorising punishment "whether committed in the court itself or elsewhere", by imprisonment or fine [5].
• Pakistan: Article 204 covers the Supreme Court and High Courts alike [3].

Divergence in definition and safeguards

• India leaves definition to statute: the Contempt of Courts Act, 1971 separates civil contempt (wilful disobedience of a court's order) from criminal contempt, caps punishment at six months' simple imprisonment or fine, and — after the 2006 amendment — permits truth in public interest as a defence [2].
• Pakistan constitutionalises the definition itself: Article 204 lists obstruction, disobedience of orders, scandalising the court and prejudicing pending matters, while protecting fair comment made in good faith [3].
• Sri Lanka has the constitutional power but no statutory definition or procedure, leaving judicial discretion unusually wide [5].

Enforcement against the executive

• The decisive difference is compliance, not text. Pakistan's contempt jurisdiction is currently being tested by a plea alleging that the government shifted jailed former PM Imran Khan to the state-run PIMS instead of the Supreme Court-ordered Shifa International Hospital [6].

Thus the region shares a near-identical constitutional grammar of contempt, but India's codified, defence-protected model offers greater legal certainty. Strengthening statutory definition, proportionate sentencing and public-interest defences — as India's 2006 reform did — would help neighbouring judiciaries use contempt as a shield for the rule of law rather than a sword against speech.