(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.