Malik, CJ.

[1] I have read the judgments prepared by learned brothers Desai and Muherji, jj. and agreed to the answers proposed by them.

[2] So far as the second question is concerned, it presents no difficulty and it is not necessary for me to add anything to what has already been said. All that the Oaths Act provides is, that nothing contained in the Oaths Act shall authorise the administration of oath to an accused person in a criminal proceeding. Reliance is not placed by the learned Government Advocate on anything in the Oaths Act to entitle him to cross-examine the contemner.

[3] The third question is a little difficult. Article 20(3) of the Constitution provides that:

"No person accused of any offence shall be compelled to be a witness against himself,"

We are concerned with the words "accused of an offence". I shall not like in this case to consider the larger question whether the words "accused of" are restrictive and mean a person against whom proceeding in a criminal court for any offence committed by him has in fact been started.

To similar provision in the Constitution of the United States though slightly differently worded, the American Courts have given a much wi