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Apology Tendered, Mitigating Circumstances of COVID-19 — (2026) INSC 470

The Appellant was under immense emotional distress during the COVID-19 pandemic, receiving hundreds of complaints from junior advocates facing starvation.

Yatin Narendra Oza v. Suo Motu, High Court of Gujarat — (2026) INSC 470

Core Argument

The Appellant was under immense emotional distress during the COVID-19 pandemic, receiving hundreds of complaints from junior advocates facing starvation. His remark 'gambling den' was a spontaneous emotional outburst, not a deliberate attack on the institution. He has repeatedly tendered unconditional apologies, which should be accepted.

Key Precedents

  • Yatin Narendra Oza v. Khemchand Rajaram Koshti (2016) 15 SCC 236 — This Court accepted the Appellant's unconditional apology in 2016 contempt proceedings, observing that 'the regret, the apology and repentance shall see the appellant in a different incarnation.'
  • Prashant Bhushan (Contempt Matter), In re (2021) 1 SCC 745 — Distinguishable because in that case the contemnor justified his statements and did not tender an unconditional apology at the earliest opportunity.
  • Mahipal Singh Rana v. State of U.P. (2016) 8 SCC 335 — The Appellant submits that the automatic disqualification under Section 24-A of the Advocates Act, 1961 is not mandatory; the court has discretion to suspend the conviction.

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