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Bharat Singh Rawat vs. Dr. Poonam Singh Rawat

Contempt Appeal (Civil) · 2026:DHC:8238-DBDecided 22 Sept 2026New Delhi Bench
CONT.APP.(C) 22/2026CNR: DLHC010453852026
Justice Prathiba M. Singh · Justice Dinesh Bhatt

Background

The appellant, a practising advocate, appealed against a single judge's order in a contempt case filed by his wife over non-payment of maintenance arrears fixed by a Family Court. The single judge's order had only directed him to comply with the earlier maintenance order and pay the arrears, without imposing any punishment for contempt.

Decision Breakdown

Relying on Supreme Court precedent (Midnapore Peoples' Coop. Bank Ltd. v. Chunilal Nanda), the Division Bench held that an appeal under Section 19 of the Contempt of Courts Act is maintainable only against an order actually punishing someone for contempt, not against an order merely directing compliance. Since no punishment had been imposed, the impugned order was not appealable under Section 19, and the appeal was disposed of, with liberty given to the appellant to separately seek clubbing of the multiple pending cases before the single judge.

Lesson Learnt

A person cannot use a contempt appeal to challenge an order that merely directs compliance without punishing for contempt; the correct remedy for such orders (if any) lies elsewhere, such as an intra-court appeal or revision.

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