DISTINCTION BETWEEN CONTEMPT IN THE FACE OF THE COURT AND CONTEMPT OUTSIDE THE COURT

• Date: 06 February 2019

"A contempt of Court is an act calculated to interfere with the administration of justice. Attorney -General v. Butterworth (1963) 1 Q.B. 696. A contempt may be either in the face of the Court (in facie curiae) or outside the Court (ex facie curiae). The former includes any word spoken or act done within the precincts of the Court which obstructs or interferes with due administration of justice or is calculated to do so. The latter, i.e. contempt ex facie curiae may be described as words spoken or published or acts done outside the Court which are intended or likely to interfere with or obstruct the fair administration of justice. See: In re: Dr. Olu Onagoruwa FCA/E/117/79. As was held in the case of Boyo v. The Attorney-General of Mid- Western State (1971) All. N.L.R. 342 a Court can deal summarily with cases of contempt in the face of the Court and by the very judicial officer in whose presence the contemnor...