the law to be substantively valid. In 2020, lawyer and activist Prashant Bhushan, along with journalist and politician Arun Shourie, and publisher N. Ram, filed a petition challenging the constitutional validity of the Contempt of Courts Act again. Also Prashant Bhushan case is a new talk of town Courts' powers to punish for criminal contempt have been repeatedly criticized by former judges and lawyers as having a chilling effect on freedom of speech, being too broad and vague in its definition and lending itself to misuse to shield the judiciary from criticism. Senior advocate Sanjay Hegde has argued that the offence of "scandalizing the court" is "incapable of precise definition," and that it derives from English law, where it has since been abolished. In 2011, retired Supreme Court judge and former Press Council of India Chairman, Markandeya Katju, called for amendments to the Contempt of Courts Act 1971 in order to allow the media to report better on law and judiciary-related matters. In March 2018, the Law Commission of India was tasked by the Government of India with re-examining Section 2 of the Contempt of Courts Act 1971, which defines the offence of contempt. The Commission was asked to examine a proposal that suggested that contempt of court should be limited to cases of civil contempt, i.e. disobedience of court orders, and should not include the offence of 'scandalising the court', i.e. criminal contempt. The Commission recommended the retention of the offence of 'criminal contempt' in India, noting that courts in India continue to use it widely, unlike other countries in which offences such as 'scandalising the court' have fallen into disuse. The Commission also noted that the power of courts to penalise contempt was inherent, and would continue to exist even if the Act was amended or deleted altogether. Notable Cases In 1978, two newspaper editors from the Times of India and the Indian Express were charged with contempt following the publication of articles that contained criticisms of the Supreme Court's decision in ADM Jabalpur v. Shivkant Shukla, a case in which the Supreme Court refused to protect the right to habeas corpus during the Emergency. The case was ultimately dropped after Chief Justice M. H. Beg, who had initiated the proceedings, was not supported by the two other judges on the bench in his opinion that contempt had been committed. In 1981, V. K. Krishna Iyer, a former