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Jagdish Chander Malik v. Manmohan Juneja

Civil Appeal · 2017 INSC 779Decided 21 Aug 2017
Civil Appeal No. 10692 of 2017
Justice Kurian Joseph · Justice Mohan M. Shantanagoudar

Background

Malik had filed a contempt petition in the Delhi High Court alleging that the Registrar of Companies (ROC) had failed to comply with an earlier court order directing it to make certain company records available to him for inspection. The High Court dismissed the contempt plea, finding no willful disobedience, noting that Malik himself had not shown up at the time and place fixed for inspection and had been "unnecessarily obstinate" about fixing an alternative date.

Decision Breakdown

The Supreme Court did not disturb the High Court's finding that there was no contempt, since the delay was substantially attributable to the appellant's own conduct. However, noting that the appellant's real objective was simply to finally obtain the documents from the ROC, the Court granted leave, disposed of the appeal, and gave him a fresh liberty to approach the ROC within two months, directing the ROC to comply with the original 2012 order without further delay once he did so.

Lesson Learnt

A contempt petition fails if the alleged "disobedience" is substantially caused by the complainant's own non-cooperation; but courts can still grant practical relief, like a fresh window to complete the original request, even while refusing to punish the other side for contempt.

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

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