Notably, earlier, Justice Anup Jairam Bhambhani had recused from hearing the plea while stating that "no act on the part of a court must in any manner have a deleterious impact on the credibility of the justice system".

It is also to be noted that Justice Bhambhani had hinted recusal in the case in March when News Broadcasters & Digital Association (NBDA) filed an intervention application. He proposed his recusal from the case due to his "past association" with the organization.

"Both of you may or may not see any bias [but] I have to have the comfort level to decide the matter," Justice Bhambhani had said. Before elevation as a Judge of the High Court, Justice Bhambhani practiced in media law and had represented NBDA on several occasions in the past.

Tanha filed the present petition in 2020 claiming that his ‘disclosure statements’ were leaked by the Delhi Police and sought an investigation into the officials' misconduct as to who leaked the information to media channels. Through the present plea, he also sought guidelines on media reporting of ongoing criminal investigations.

Case Title: Asif Iqbal Tanha (Through Pairokar) vs. State of NCT of Delhi & Ors.