Vann Nath was among seven known Tuol Sleng survivors.
Judges will have to consider this weeks’ hearings, a process that will likely push back the start date of a full trial.
The contempt proceedings represent the first time the court has actively pursued a media organization for its reporting on the tribunal.
VOA issued a statement of concern about the potential “chilling effect” the threat could have on media coverage of the tribunal.
Wednesday’s statement opened broader questions over the court’s work and the role of journalists who cover it.
The trial of Duch, who admitted his guilt and asked for the forgiveness of his victims, was a first for the court.
Three of those facing prosecution may finally face justice after many years in the Khmer Rouge tribunals.
The court is holding three days of hearings to determine the fitness of three former leaders later this year or into the next.
A tribunal official told the former soldiers in Samlot that the two cases were still under consideration at the tribunal.
Tan Sokhun, a doctor and head of the technical section of La Sante said there was little hope of recovery.
Next week, the court will discuss recent medical reports examining the physical abilities of three defendants to stand trial.
Allowing the publication of that submission will further help victims who wish to be a part of the case, tribunal monitors said Monday.