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2026 Supreme(SC) 13

SUPREME COURT OF INDIA
VIKRAM NATH, SANDEEP MEHTA, JJ.
Dharmendra Sharma – Petitioner
Versus
M. Arunmozhi & Anr. – Respondent(s) / Alleged Contemnor(s)
Contempt Petition (C) Nos. 703-704 of 2025 In Civil Appeal Nos. 2809-2810 of 2024
Decided On : 05-01-2026

Advocates appeared:
For the Petitioner(s): Mr. Vipin Sanghi, Sr. Adv. Mr. Om Prakash, Adv. Mr. Vikas Singh Jangra, AOR
For the Respondent(s): Mr. Sudhir Kulshreshtha, AOR Mr. Shaurya Sahay, AOR Mr. Aman Jaiswal, Adv. Ms. Palak Mathur, Adv.

The court affirmed the necessity of compliance with judicial directives, ordering a refund despite statutory limitations on stamp paper refunds.

Headnote:(A) Contempt of Courts Act, 1971 - Compliance with Court Directions - Petitioner alleged that the respondent failed to comply with the Supreme Court's earlier judgment regarding refund of non-judicial stamp paper costs. Court emphasized adherence to its directive and ordered refund within two months. (Paras 8 and 9)

(B) Limitation for Refund - The ruling highlighted that refusal to refund exceeded statutory limitations set by state rules but acknowledged the need for adherence to court directives. (Paras 3, 4 and 7)

Facts of the case:
The petitioner initiated contempt petitions asserting that the respondent did not refund costs for unused stamp papers following a previous directive for compensation. Petitioner addressed the concerned registration authority, which denied the refund based on statutory limitations. (Paras 2 and 3)

Findings of Court:
The Court directed the respondent to refund the stamp paper cost, underlining its authority over compliance with its orders, despite prior limitations cited by the state. (Paras 7 and 8)

Issues: The main questions pertain to the non-compliance of directions issued in a previous judgment regarding the refund of stamp papers and the adoption of correct interpretations of the related legal statutes. (Paras 5 and 6)

Ratio Decidendi: The court ruled that despite limitations on physical stamp refunding, compliance with judicial orders is paramount, emphasizing justice over procedural lapses. (Paragraphs 7 and 8)

Result: Contempt petitions allowed with directions for refund.

Table of Content
1. failure to comply with earlier court directions (Para 1 , 2)
2. petitioner's claim for refund of stamp costs (Para 3 , 4)
3. involvement and response of state of uttar pradesh (Para 5 , 6 , 7)
4. court's directive for refund of stamp costs (Para 8)
5. closure of contempt petition (Para 9 , 10)

JUDGMENT

VIKRAM NATH, J.

1. Heard Shri Vipin Sanghi, learned senior counsel for the petitioner and learned counsel appearing for the respondents.

2. The present contempt petitions have been instituted by the appellant in the civil appeals already disposed of, alleging, inter alia, that respondent no. 1 has willfully failed to comply with the directions issued by this Court in its judgment dated 6th September, 2024, rendered in Dharmendra Sharma v. Agra Development Authority, reported in (2025) 1 SCC 422. The relevant portion of the judgment germane to the controversy at hand is reproduced hereinbelow: -

    “34. In light of the aforementioned observations and taking into account the shortcomings on the part of both the appellant and ADA, this Court deems it appropriate to provide a compensation of Rs 15,00,000 (Rupees fifteen lakhs only) apart from what was awarded by NCDRC. Therefore, apart from the refund of the entire amount deposited by the appellant @ 9% interest per annum from 11-7-2020 till the date of refund, ADA is directed to pay an additional amount of Rs 15,00,000 (Rupees fifteen lakhs only) to the appellant. The entire amount should be rendered to the appellant within three months of this order. We also order ADA to return the non-judicial stamp worth Rs 3,99,100 back to the appellant.

    . . .

    35. Furthermore, we refrain from imposing any exemplary costs on either party, recognising that both have contributed to the situation at hand. It is also to be noted that ADA, being a civic body tasked with serving the public and operating on a non-profit basis, should not be unduly penalised in a manner that could impede its functioning.

    36. Civil Appeals Nos. 2809-10 of 2024 are disposed of accordingly.”

3. The petitioner submits that although respondent no. 1 has complied with the remaining directions issued by this Court, namely, refunding the entire amount deposited by the petitioner along with interest at the rate of 9% per annum, and paying an additional sum of Rs. 15,00,000/- (Rupees Fifteen Lakhs only), however the respondent has failed to refund an amount of Rs. 3,99,100/- (Rupees Three Lakhs Ninety-Nine Thousand One Hundred only), being the cost of the non- judicial stamp papers purchased by the petitioner. It is further averred that, instead of refunding the said amount, respondent no. 1, on 7th December, 2024, returned the twenty-two original stamp papers, which had in the meanwhile expired, through postal communication.

4. According to the petitioner, he addressed representations to the Assistant Commissioner of Stamps, Agra, seeking refund of the amount paid towards the unused twenty-two original stamp papers. However, the Assistant Inspector General of Registration, Agra, by order dated 21st July, 2025, rejected the petitioner’s request for refund of the stamp value, informing him that the same was not refundable. The relevant extract of the said order reads as under: -

    “Regarding the refund of physical non-judicial stamp papers, it is regretfully informed that physical non- judicial stamp papers can be refunded within a maximum period of eight years from their date of purchase.

    . . .

    As it evident from the above, the concerned notification came into effect in the state from 20th December 2017, and it is clarified in the notification that no application for stamp refund will be accepted one year after the date of the amendment in cases where the decision for the stamp refund is required to be taken by the state government.

    You first submitted the application for the refund of the stamp value to this office on 20.12.2024. By that date, approximately 10 years had elapsed since you purchased the stamps. Therefore, following t

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