court are similarly liable.

(f) Contempt in _facie curiae_. "Some contempts," says Blackstone, "may
arise in the face of the court, as by rude and contumelious behaviour,
by obstinacy, perverseness or prevarication, by breach of the peace, or
any wilful disturbance whatever"; in other words, direct insult to or
interference with a sitting court is treated as contempt of the court.
It is immaterial whether the offender is juror, party, witness, counsel,
solicitor or a stranger to the case at hearing, and occasionally it is
found necessary to punish for contempt persons under trial for felony or
misdemeanour if by violent language or conduct they interrupt the
proceedings at their trial. Judges have even treated as contempt the
continuance outside the court-house after warning of a noise sufficient
to disturb the proceedings of the court; and in Victoria Chief Justice
Higginbotham committed for contempt a builder who persisted after
warning in building operations close to the central criminal court in
Melbourne, which interfered with the due conduct of the business of the
sittings.

(g) Attempts to prevent or interfere with the due course of justice,
whether made by a person interested in a particular case or by an
outsider. This branch of contempt takes many forms, such as frauds on
the court by justices, solicitors or counsel (e.g. by fraudulently
circularizing shareholders of a company against which a winding-up
petition had been filed), tampering with witnesses by inducing them
through threats or persuasion not to attend or to withhold evidence or
to commit perjury, threatening judge or jury or attempting to bribe them
and the like; and also by "scandalizing the court itself" by abusing
the parties concerned in a pending case, or by creating prejudice
against such persons before their cause is heard.

Invectives against judges.

The _locus classicus_ on the subject of contempt by attacks on judges is
a judgment prepared by Sir Eardley-Wilmot in the case of an application
for an attachment against J. Almon in 1765, for publishing a pamphlet
libelling the court of king's bench. The judgment was not actually
delivered as the case was settled, but has long been accepted as
correctly stating the law. Sir Eardley-Wilmot said that the offence of
libelling judges in their judicial capacity is the most proper case for
an attachment, for the "arraignment of the justice of the judges is
arraigning the king's justice; it