Latest JudgementContempt of Courts Act, 1971

Rajan Chadha & Anr. v. Sanjay Arora, 2025

The Subject matter revolves around that the Judicial propriety and limits of jurisdiction among coordinate benches in contempt proceedings.

Supreme Court of India·26 April 2025

Contempt of Courts Act, 1971

Court

Supreme Court of India

Date of Decision

26 April 2025

Judges

Justice B.R. Gavai ⦁ Justice Augustine George Masih

Citation

Acts / Provisions

Section 13(1)(ia), Hindu Marriage Act, 1955

Section 25, Hindu Marriage Act, 1955

Facts of the Case

The case stemmed from a commercial dispute involving RBT Private Ltd., in which the appellants alleged that Sanjay Arora, the respondent, had violated court and arbitral orders arising out of obligations under a Memorandum of Understanding (MoU).
In December 2023, a Single Judge of the Delhi High Court found the respondent guilty of contempt and granted time for him to purge the contempt.
However, following a roster change, another Single Judge of the same High Court bench later dismissed the contempt petition, ruling that no contempt had been committed. This judgment effectively reversed the earlier contempt finding.
The Aggrieved, the appellants approached the Supreme Court, arguing that such re-evaluation by a coordinate bench is impermissible.

Whether a Single Judge of a High Court can overturn or re-examine a finding of contempt made by another Single Judge of the same court.
Whether such action amounts to an appellate review over a coordinate bench’s order, violating judicial propriety.
What is the correct procedure for challenging a contempt finding in a High Court?

It is impermissible for a coordinate bench (i.e., a bench of equal strength) of a High Court to review, reconsider, or overturn the findings of another coordinate bench, especially in contempt matters. Doing so undermines judicial discipline and violates the doctrine of finality and institutional integrity.
A Single Judge cannot exercise appellate or review jurisdiction over an order passed by another Single Judge. Such actions amount to a transgression of judicial limits, as only a Division Bench or appellate forum can review or reverse such orders.
Once contempt is established by a competent court, the legal course that follows is limited to determining: Whether the contemnor has purged the contempt, and The quantum or nature of punishment to be imposed, if necessary.
If a party is aggrieved by a finding of contempt, the appropriate remedy is to appeal under Section 19 of the Contempt of Courts Act, 1971, and not to approach another bench of equal standing.
The second judgment of the Delhi High Court is quashed, and the matter is remanded to the same High Court to resume proceedings from the stage immediately following the initial contempt finding made on 5th December 2023.

The judgment upholds the principle of judicial discipline and reinforces the doctrine of coordinate bench authority, ensuring consistency and respect for hierarchy within the same court.
The Court’s reasoning emphasizes that legal certainty and respect for judicial orders are fundamental to the rule of law. By disallowing a second bench from revisiting the contempt finding, the Court protects the sanctity of judicial decisions and prevents forum shopping or manipulation through roster changes.
The ruling also reinforces the correct procedural path — that challenges to contempt findings must go through appellate channels, not via parallel or subsequent proceedings before another Single Judge.
This judgment is crucial in maintaining institutional integrity, especially in High Courts where frequent roster changes could potentially allow conflicting findings on the same issue if not regulated by judicial discipline.