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Rajan Chadha and Another v. Sanjay Arora

Not available · 2025 INSC 546Decided 23 Apr 2025
Not available
Justice B.R. Gavai · Justice Augustine George Masih

Background

The appellants and respondent were shareholders and directors of a company; under a 2019 settlement agreement, the respondent was to buy out the appellants' shares and run the company, with disputes to go to arbitration. When the respondent allegedly failed to honour the agreement's terms (including operating a competing business from the company's premises and not paying loan instalments), the appellants sought and obtained interim protective orders from the Delhi High Court and an arbitrator. The appellants then filed a contempt petition alleging the respondent violated these orders: one Single Judge of the High Court found the respondent guilty of contempt in December 2023 and gave him a chance to purge it, but when the matter came before a different Single Judge (after a change in roster), that judge reversed course and held there was no contempt, discharging the show-cause notice.

Decision Breakdown

The Supreme Court held that once one judge of the High Court had conclusively found the respondent guilty of contempt and merely adjourned the matter to let him purge it or explain why he shouldn't be punished, a second judge taking over the case could not revisit and overturn that finding of guilt, doing so effectively meant one judge sat in appeal over a coordinate judge's decision, which is impermissible and against judicial propriety. If the respondent believed the first contempt finding was wrong, his only remedy was a statutory appeal under Section 19 of the Contempt of Courts Act, not a fresh hearing before another judge of the same court. The Supreme Court set aside the second judge's order and sent the matter back to be considered strictly from the stage after the December 2023 contempt finding.

Lesson Learnt

Once a court has made a definitive finding on a legal question (such as guilt in contempt proceedings), a change of judge or bench within the same court cannot be used to reopen and reverse that finding: the only proper route to challenge it is a formal appeal, preserving consistency and discipline in judicial decision-making.

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

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