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Gurudeep Singh vs Regonda Srinivas & Ors. (2023 INSC 617)

Not available · 2023 INSC 617Decided 4 Jul 2023
Not available
B.V. Nagarathna · Prashant Kumar Mishra

Background

NTPC Ltd. had been directed by the Telangana High Court in 2021 to complete, within two months, a recruitment process for "Junior Mazdoor" posts meant for land oustees whose land NTPC had earlier acquired. Instead of completing recruitment under the existing 2017 notification, NTPC's Chairman and General Manager (the appellants) cancelled it and issued a fresh notification in 2022. The land-oustee applicants, feeling shortchanged, filed a contempt case, and the High Court held the two NTPC officials in contempt, sentencing them to two months' simple imprisonment plus a fine, refusing to accept their unconditional apology.

Decision Breakdown

The Supreme Court held that the original High Court order only fixed a timeline for completing recruitment. It never specified that the recruitment had to proceed under the old 2017 notification. Since issuing a fresh notification was not expressly barred, doing so could not amount to "deliberate and wilful" disobedience of the court's order, which is the necessary ingredient for contempt. The Court also found fault with the High Court for rejecting the officials' unconditional apology without adequate justification, especially given the ambiguity in what exactly was ordered. It therefore accepted the apology, set aside the sentence, and allowed the appeals.

Lesson Learnt

Contempt of court requires proof of deliberate and wilful disobedience of a specific, unambiguous direction: good-faith compliance through an alternative reasonable route, especially where the original order was silent on the method, will not attract punishment for contempt.

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

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