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Abhishek Kumar Singh v. G. Pattanaik & Ors.

Contempt Petition (Civil) · 2021 INSC 305Decided 3 Jun 2021
Contempt Petition (Civil) Nos. 625-626 of 2019
Justice A.M. Khanwilkar · Justice B.R. Gavai

Background

Following an earlier Supreme Court judgment directing the Uttar Pradesh Jal Nigam (a state water corporation) to pass a fresh, reasoned order on the employment status of certain engineers and staff whose appointments had been under a cloud (after a High Court finding of irregularities), the Jal Nigam first reinstated the petitioners but later, after further inquiry, issued a fresh termination order in March 2020, concluding it was not possible to separate "tainted" from "untainted" appointees. The petitioners filed multiple contempt petitions alleging the Jal Nigam had wilfully disobeyed the Supreme Court's earlier directions by terminating them without individual hearings, along with a writ petition and a transfer petition seeking consolidation of related disputes.

Decision Breakdown

The Supreme Court held that its earlier order only required the Jal Nigam to give petitioners a hearing if it was possible to segregate tainted from untainted candidates; since the Jal Nigam, after detailed inquiry (including an SIT report), concluded such segregation was not possible and annulled the entire selection process on that basis, there was no wilful disobedience of the Court's earlier directions in skipping individual notices. The Court therefore discharged the show-cause notices and dismissed all the contempt petitions, while declining to rule on the correctness of the Jal Nigam's termination order itself since that question was already pending before the Allahabad High Court in separate writ petitions filed by similarly affected employees. It also rejected the transfer petition and relegated the petitioners to pursue their own writ petition before the High Court, directing that Court to hear all overlapping cases together.

Lesson Learnt

A contempt petition only succeeds if there is wilful, deliberate disobedience of a court's specific direction: if an authority's later action is a reasonable, good-faith response consistent with the liberty the court actually granted it, that action cannot be punished as contempt, even if the affected persons disagree with the outcome on the merits.

Official source (sci.gov.in)View Judgment (PDF)

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