§ 755. When punishment may be summary. Where the offense is committed
in the immediate view and presence of the court, or of the judge or
referee, upon a trial or hearing, it may be punished summarily. For that
purpose, an order must be made by the court, judge, or referee, stating
the facts which constitute the offense and which bring the case within
the provisions of this section, and plainly and specifically prescribing
the punishment to be inflicted therefor. Such order is reviewable by a
proceeding under article seventy-eight of the civil practice law and
rules.