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Naima Khatoon vs. Utpal Chakraborty & Anr.

Contempt Case (Civil) · 2026:DHC:8125Decided 21 Sept 2026New Delhi Bench
CONT.CAS(C) 99/2018CNR: DLHC010388082018
Justice Harish Vaidyanathan Shankar

Background

Earlier High Court orders (from 2015 and 2017) had restricted the respondents, who managed certain "enemy property" (property linked to persons who migrated to Pakistan, regulated under special law), from collecting rent from tenants pending resolution of an ownership dispute. The petitioner alleged the respondents violated these orders by issuing a rent receipt in 2017 and by collecting on certain cheques from tenants.

Decision Breakdown

The Court found that two specific cheques relied upon had never actually been presented for encashment, so no contempt arose from them. However, a receipt dated 30.11.2017 for Rs. 1,00,320 remained unclear as to whether that amount was actually collected. The Court did not impose a contempt penalty but directed that if the amount had indeed been realized by the respondents in violation of the earlier orders, it must be refunded to the petitioner with 12% annual interest within eight weeks.

Lesson Learnt

Contempt proceedings are not always about punishing someone: courts can instead use them to identify any actual gains made in violation of a court order and simply direct restitution of that amount with interest, especially where the evidence of deliberate defiance is unclear.

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