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Bajrang Lal Sharma v. C.K. Mathew and Ors.

Contempt Petition (Civil) · 2020 INSC 79Decided 23 Jan 2020
Contempt Petition (Civil) Nos. 453-454 of 2012
Justice Uday Umesh Lalit · Justice Indira Banerjee · Justice M.R. Shah

Background

A Rajasthan Administrative Service officer had earlier succeeded in getting certain seniority notifications (that gave SC/ST candidates consequential seniority without the required "quantifiable data") quashed by the Supreme Court in an earlier round of litigation. When the Rajasthan government issued a fresh notification in 2011 based on a committee's report, the officer filed these contempt petitions alleging the state had deliberately defied the Court's earlier directions by continuing to apply the superseded approach to seniority and promotions.

Decision Breakdown

The Supreme Court held that the state's issuance of the 2011 notification, based on the Bhatnagar Committee's data-collection exercise, was a genuine (if slow) attempt to comply with the Court's earlier directions, not a wilful or deliberate defiance warranting contempt, and that this very notification had already been examined and not found contemptuous in an earlier Supreme Court decision (Salauddin). The Court further noted that a separate substantive challenge to the 2011 notification and the committee's report was still pending before the Rajasthan High Court, which was the proper forum to test its validity, not a contempt proceeding. It also noted that a Constitution Bench ruling (Jarnail Singh) had meanwhile altered the legal landscape on the "quantifiable data" requirement. The Court closed the contempt petitions and requested the High Court to decide the pending substantive case expeditiously.

Lesson Learnt

Contempt of court requires proof of wilful, deliberate defiance of a court's directions: genuine, good-faith compliance efforts (even if slow or imperfect) do not amount to contempt, and disputes about whether a government's compliance measure is legally correct belong in a substantive case, not a contempt proceeding.

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

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