If a matter is under police investigation and no arrest is made, comments on that do not constitute a contempt of court. But when an accused is under custody, even if he has so far not been committed for trial or produced before a magistrate, comments can fall within the mischief of the contempt law.
“Just as it is a legal offence to place a false label on goods, so it is a moral offence to put misleading headlines on news.” So far as court news are concerned, they may constitute a legal offence, even if the actual report is accurately given.
Contempt of court can also be committed through advertisement. Announcement of reward of discovering legal proof or for certain evidence in constitute contempt of court. Similarly publishing advertisement for demonstration against a judge is a contempt of court.
There are many types of contempt, summarized by Mr. Tek Chand and H.L Sarin (a) Comments on the conduct of petitioner in lunancy proceedings, (b) comments on the conduct of a debtor in bankruptcy proceedings, (d) comments on prisoners, (d) imputation of fraud or dishonesty, (e) charge of undue influence, (f) making libelous statements on parties or witnesses, (g) comments against conduct of defendant, (h) abusing persons making affidavits, (i) making allegation of perjury, (j) making suggestions that plaintiffs case is untenable, (k) reflection on goods supplied by the plaintiff, (i) disputing validity of a patent in a newspaper during pendency of suit, (m) advertisement offering reward for securing evidence in a pending matrimonial suit, (n) advertisement as to proof of adultery of wife; (o) publication before hearing of documents connected with the case, (p) publication of inaccurate proceedings,; (q) theatrical impersonation of prisoner, (r) issuing circulars attacking directors or liquidators, (s) publication and comments on proceedings heard in camera, (t) publication of article after conviction but before judgement, (u) inserting paragraph anticipating result of a pending case, (v) making references to a case only for political purposes without mentioning the names of the parties in action (w) preaching a sermon in chapel on the subject-matter of a pending action (x) publishing photograph of an accused where question of his identification is involved, (y) publishing beforehand what purports to be the defence to be put forward by an accused person (z) displaying misleading headlines, and (zi) conduct an independent investigation into a crime for which a person has been arrested and publishing the result of that investigation.