Contempt proceedings must meet stringent standards; ambiguity in court orders can prevent a finding of contempt without clear and definitive directions.

JUDGMENT :

Sabyasachi Bhattacharyya, J.

1. Affidavit-of-service filed today be kept on record.

2. The present challenge has been preferred against an order dated June 20, 2025, whereby a contempt application filed by the private respondent was allowed by the West Bengal Land Reforms and Tenancy Tribunal, thereby directing the alleged contemnor, that is, the B.L. & L.R.O, Kalna-I, Purba Bardhaman to file show cause as to why contempt proceedings shall not be drawn up against him vide Section 15 of the WEST BENGAL LAND REFORMS AND TENANCY TRIBUNAL ACT for wilful and deliberate violation and disregard of the solemn order dated September 28, 2022 passed by the said Bench of the Tribunal in connection with O.A. No. 1980 of 2019 (LRTT) by not disposing of the application of the applicant and not concluding the hearing in terms of the order of the Hon’ble High Court at Calcutta, as well as against an order dated July 11, 2025, whereby, keeping in view that a fair chance should be given to the concerned B.L. & L.R.O since he had joined only 10 days back, the said B.L. & L.R.O was directed to complete the compliance proceeding and to bring the corrected ROR in person before the said Bench in terms of the judgment of this Hon’ble Court positively on the next date fixed.

3. Learned Senior Government Advocate, appearing for the petitioner/State, submits that the order passed by the B.L. & L.R.O, which was the premise of the rule of contempt issued against him, substantially complied with the direction of the Tribunal. Taking this Court through the order of the Tribunal dated September 28, 2022, which has been allegedly violated, learned Senior Government Advocate points out that apart from a direction on the B.L. & L.R.O to dispose of the representation of the applicant/private respondent in terms of the observation made by this Court vide order dated August 10, 1992 in C.O. No. 11078(W) of 1992, the Tribunal further directed the B.L. & L.R.O to meticulously verify whether the correction of records of rights at the behest of the applicant/private respondent herein can be made in accordance with law and relevant rules existing. Thus, it is contended that the concerned B.L. & L.R.O, while passing the order, which is allegedly contumacious, comprehensively dealt with the law on the substance of the dispute and came to the finding, upon a consideration of several judgments cited before him, that the decrees of the civil appellate courts were nullities and, as such, the correction could not be effected in terms of the same in respect of the records of rights concerned.

4. It is argued that in view of the rider of the order of the Tribunal to the effect that the B.L. & L.R.O was to meticulously verify whether the correction of the records of rights could be made in accordance with the law and relevant rules, the B.L. & L.R.O acted well within the ambit of the said direction in passing the impugned order, considering the legality and the relevant rules. It is sought to be argued by the learned Senior Government Advocate that in view of the unamended Section 46 of the West Bengal Estates Acquisition Act, 1953 being applicable, it was beyond the scope of the civil court to decide the issues involved and, as such, the B.L. & L.R.O could not be said to have committed contempt of court by passing a well-reasoned order in accordance with law.

5. The learned Senior Government Advocate next argues that in the event the private respondent is aggrieved by the order of the B.L. & L.R.O, a fresh challenge against the same is the approp