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Israr Ahmad Khan v. Ms. Richa Sharma

Contempt Petition · 2026 INSC 209Decided 24 Feb 2026
CONMT.PET.(C) No.-000005 - 2026
Justice Ahsanuddin Amanullah · Justice R. Mahadevan

Background

The petitioner had filed contempt proceedings alleging that Chhattisgarh government officials failed to comply with a Supreme Court order dated 20.05.2025 (passed in related civil appeals) within the three-month deadline set by the Court. The named respondents (originally Mr. Amarnath Prasad and Mr. V. Sreenivasa Rao) were substituted during the hearing with the officers actually holding the relevant posts: Ms. Richa Sharma, Additional Chief Secretary, Forest and Climate Change, and Mr. Anil Kumar Sahu, since the final compliance decision rested with them. The alleged contemnors admitted in their affidavit that compliance had not happened, citing "administrative hurdles," and had instead filed a defective, delayed Review Petition against the original order rather than complying with it.

Decision Breakdown

The Supreme Court held that a clear, prima facie case of contempt was made out, since the officers had effectively admitted non-compliance while offering what the Court called "inexcusable justifications." It held that filing a Review Petition does not excuse non-compliance with a Court order: the order must be obeyed first, and any relief sought through review or otherwise cannot be made a precondition for compliance. The Court reaffirmed (citing Sita Ram v. Balbir and other precedents) that even persons not originally party to an order can be held liable for contempt if they knowingly assist in its breach, and that a contempt court only examines whether an order was complied with, not whether it was correct. Rather than immediately framing charges, the Court granted the officers one final 15-day-extended opportunity (adjourning to 24.03.2026) to fully comply, on their personal undertaking, failing which charges would be framed and they would have to appear in person.

Lesson Learnt

A Supreme Court order must be complied with even while a review petition against it is pending: merely filing a review, especially a defective or delayed one, is not a valid excuse for non-compliance, and government officers (including those who take over a post later) remain personally accountable for enforcing court orders.

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

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