The Supreme Court reaffirmed that contempt proceedings are subject to strict limitation periods, and the concept of a continuing wrong does not apply to single acts of non-compliance with court orders. The court also underscored the importance of adhering to procedural rules governing review jurisdiction.

JUDGMENT :

DIPANKAR DATTA, J.

CIVIL APPEAL NOS. 7920-7921 OF 2024

[ARISING OUT OF SLP (CIVIL) NOS. 19647-48 OF 2022]

Leave granted.

2. These appeals assail the common judgment and order dated 27th April, 2022¹[impugned order, hereafter] of the High Court for the State of Telangana at Hyderabad²[High Court, hereafter] allowing Review I.A. No. 1/2020 in LPA 1/2018 and Review I.A. No. 3/2020 in CA 33/2017³[review petitions, hereafter] preferred by the first respondent. The impugned order of the High Court recalled the order under review and dismissed a contempt appeal as well as a letters patent appeal of the appellant.

3. The present dispute emerges from a complex and interwoven set of legal proceedings, involving myriad parties and decisions rendered by both judicial and quasi-judicial authorities. The factual matrix, to the extent relevant for adjudication of these civil appeals, is noticed hereunder:

I. Ms. Sultana Jahan Begum, daughter of Nawab Moin-ud-Dowla Bahadur, instituted Original Suit 130/1953⁴[civil suit, hereafter] (since renumbered as Civil Suit 07/1958 upon its transfer to the High Court) before the City Civil Court, Andhra Pradesh, seeking partition of her father’s properties known as ‘Asman Jahi Paigah’.

II. On 06th April, 1959, a preliminary decree was passed by the High Court on the basis of a compromise entered into by and between the parties to the civil suit. The schedule of properties included within it Raidurg village⁵[subject land, hereafter].

III. Notably, it is recorded therein that the plaintiff chose to withdraw her claim against, inter alia, the defendant no. 48 in the suit, i.e., the Secretary, Finance Department of the Government of Andhra Pradesh. Resultantly, the suit stood dismissed against the State unconditionally.

IV. During the pendency of the civil suit, Nawab Zaheer Yar Jung, son of Nawab Moin-ud-Dowla Bahadur, filed a claim petition before the Nazime- Atiyat, claiming the subject land as jagir land. This claim was negatived by the Nazim-e-Atiyat vide an order dated 28th October, 1968 upon verification of sanad, which revealed that there did not exist any document granting paigah with respect to the subject land to the claimant’s father.

V. The order passed by the Nazim-e-Atiyat, upon appeal, was confirmed by the Board of Revenue vide an order dated 29th December, 1976, which held that the subject land stood escheated to the Government.

VI. Meanwhile, on 01st October, 2003, the decree holders in the civil suit executed a deed of assignment in favour of the first respondent herein in respect of land measuring more or less Ac 143.00 guntas forming part of certain survey numbers of the subject land.

VII. On 26th December, 2003, the High Court passed the final decree and judgment in the civil suit in favour of the first respondent, with respect to land measuring more or less acres 84.30 guntas⁶[decretal property] forming part of Survey No. 46 of the subject land.

VIII. Pursuant thereto, the first respondent had approached the Tahsildar with a prayer for mutation of his name in respect of the decretal property in the revenue records which proved abortive. Consequently, the first respondent invoked the writ jurisdiction of the High Court by preferring Writ Petition 1729/2009⁷[writ petition, hereafter], seeking direction for effecting mutation in terms of the final decree in the civil suit. The respondent’s writ petition was heard with a connected matter being Writ Petition 581/2009.

IX. On 05th March, 2009, a Single Judge of the High Court vide a common order disposed of both the writ petitions at the admission stage itself, with the following order:

“A partial final decree was passed by this Court on 26.12.2003 in Application No.1409 of 2003 in C.S. No. 7 of 1958, directing several steps. One of the steps is that the names of the decree holders be mutated in respect of the property mentioned in the decree. It appears that the persons, who have purchased part of the property from the parties to the decree, hav