dience; and for purposes
of appeal orders dealing with these forms of contempt have hitherto been
treated as civil proceedings.

(b) Disobedience by inferior judges or magistrates to the lawful order
of a superior court. Such disobedience, if amounting to wilful
misconduct, would usually give ground for amotion or removal from
office, or for prosecution or indictment or information for misconduct
(Archbold, _Criminal Pleading_, 147, 23rd ed.).

(c) Disobedience or misconduct by executive officers of the law, e.g.
sheriffs and their bailiffs or gaolers. The contempt consists in not
complying with the terms of writs or warrants sent for execution. For
instance, a judge of assize having ordered the court to be cleared on
account of some disturbance, the high sheriff issued a placard
protesting against "this unlawful proceeding," and "prohibiting his
officer from aiding and abetting any attempt to bar out the public from
free access to the court." The lord chief justice of England, sitting in
the other court, summoned the sheriff before him and fined him L500 for
the contempt, and L500 more for persisting in addressing the grand jury
in court, after he had been ordered to desist. A sheriff who fails to
attend the assizes is liable to severe fine as being in contempt
(Oswald, 51). And in Harvey's case (1884, 26 Ch. D. 644) steps were
taken to attach a sheriff who had failed to execute a writ of attachment
for contempt of court in the mistaken belief that he was not entitled to
break open doors to take the person in contempt. The Sheriffs Act 1887
enumerates many instances in which misconduct is punishable under that
act, but reserves to superior courts of record power to deal with such
misconduct as a contempt (s. 29).

(d) Misconduct or neglect of duty by subordinate officials of courts of
justice, including solicitors. In these cases it is more usual for the
superior authorities to remove the offender from office, or for
disciplinary proceedings to be instituted by the Law Society. But in the
case of an unqualified person assuming to act as a solicitor or in the
case of breach of an undertaking given by a solicitor to the court,
proceedings for contempt are still taken.

(e) Misconduct by parties, jurors or witnesses. Jurors who fail to
attend in obedience to a jury summons and witnesses who fail to attend
on subpoena are liable to punishment for contempt, and parties, counsel
or solicitors who practise a fraud on the