IN THE HIGH COURT OF DELHI AT NEW DELHI
PRATHIBA M. SINGH, MADHU JAIN, JJ.
Dalbir Singh Yadav And Ors. - Appellants
Versus
Rajdarbar Heritage Ventures Ltd. - Respondent
CONT.APP.(C) 7 of 2026, CM APPL. 8948 of 2026
Decided On : 10-02-2026
| Table of Content |
|---|
| 1. background of the contempt appeal. (Para 2 , 3 , 4 , 5 , 6 , 7 , 8) |
| 2. arguments on maintainability and contempt violations. (Para 10 , 11 , 12) |
| 3. analysis of appealability under section 19 of the contempt act. (Para 13 , 19) |
| 4. established ratio on appealable orders in contempt cases. (Para 14 , 15 , 16) |
| 5. final decision on the appeal's maintainability. (Para 26 , 27 , 28) |
JUDGMENT :
Prathiba M. Singh, J.
1. This hearing has been done through hybrid mode.
2. The present appeal has been filed by the Appellants under Section 19 of the Contempt of Courts Act, 1971, inter alia, assailing the impugned order dated 14th January, 2026 passed by the ld. Single Judge inCONT.CAS(C) No. 1822/2025 titled ‘Rajdarbar Heritage Venture ltd. v. Dalbir Singh Yadav’(hereinafter, ‘impugned order’).
3. The background of the present case is that, an arbitration petition being O.M.P. (I) (Comm.) NO. 335/ 2024 under Section 9 of the Arbitration and Conciliation Act, 1996 (hereinafter, ‘the Arbitration Act’) was filed by the Respondent before the ld. Single Judge. The same was based upon the ‘Collaboration Agreement’ dated NIL of 2001. Vide order dated 30th September, 2024 (hereinafter, ‘the status quo order’) the ld. Single judge had directed as under:
“12. In the meantime, status quo shall be maintained by the parties as regards title and possession of the land forming part of the Collaboration Agreement. It is made clear that this order shall not affect the rights of the acquiring authority and/ or affect any other pending legal proceeding qua the acquisition of the land in question”.
4. Pursuant thereto, the Respondent had also filed ARB.P. No. 64/2025 under Section 11 of the Arbitration Act before the ld. Single Judge. Vide order dated 10th October, 2025 the ld. Single Judge had appointed an arbitrator in the matter.
5. On the same day i.e., 10th October, 2025, vide a separate order in O.M.P. (I) (Comm.) NO. 335/ 2024, ld. Single Judge had considered the petition under Section 9 of the Arbitration Act and directed that the status quo order dated 30th September, 2024 shall continue, till varied, modified or upheld by the arbitrator.
6. Thereafter, the Appellants challenged the order dated 10th October, 2025 in ARB.P. No. 64/2025, appointing the arbitrator, before the Supreme Court. In SLP (C) No. 36941/2025 titled, Dalbir Singh Yadav & Ors. v. Rajdarbar Heritage Ventures Ltd. the order dated 16th January, 2026 was passed by the Supreme Court. The said order reads as under:
“1. Application for exemption from filing Certified Copy of the Impugned judgment is allowed.
2. Issue notice.
3. Ms. Jaikriti S. Jadeja, learned counsel accepts notice on behalf of the respondent.
4. Counter affidavit be filed within four weeks. Rejoinder thereto, if any, be filed within two weeks thereafter.
5. In the meantime, operation of the impugned order shall remain stayed.
6. List after six weeks.”
7. In terms of the above order, the arbitral proceedings have been stayed.
8. However, the status quo order dated 30th September, 2024 continues to operate. The Respondent filed CONT.CAS(C) No. 1822/2025 on the ground that status quo order dated 30th September, 2024 and order dated 10th October, 2025 in O.M.P. (I) (Comm.) NO. 335/ 2024 was violated by the Appellants. In the said contempt case, vide order dated 14th January, 2026, the ld. Single Judge directed as under:
“1. Learned senior counsel for the petitioner submits that in violation of the directions contained in the order dated 30.09.2024 and 10.10.2025 passed in OMP (I)(COMM) 335/2024, the respondents have disrupted the status quo in respect of the land in question. He draws attention to certain photographs to substantiate that certain third parties who were not in occupation of the premises at the time of filing of the aforementioned petition have now been inducted into the subject property.
2. In the above circumstances, let the respondent furnish details of the tenants / occupants inducted into the property
Ajay Kumar Bhalla & Ors. v. Prakash Kumar Dixit
Tamilnad Mercantile Bank Shareholders Welfare Association v. S.C. Sekar and Others.
An appeal under Section 19 of the Contempt of Courts Act is maintainable only against orders imposing punishment for contempt; non-punitive orders are not appealable.
The court clarified that in contempt proceedings, the judge's role is limited to assessing compliance with prior orders, not issuing new directives, emphasizing the maintainability of appeals under S....
An appeal under Section 19 of the Contempt of Courts Act, 1971, is maintainable against any order in contempt proceedings, not just punitive orders.
The main legal point established in the judgment is the limitation on the appealability of a contempt Judge's order under Section 19 of the Contempt of Courts Act and Chapter VIII Rule 5 of the Rules....
Contempt of court - LPA against the orders passed in contempt petition is not maintainable as said orders are interlocutory in nature.
The contempt jurisdiction is to ensure compliance with the order of the Writ Court and cannot be used to review or challenge the correctness of the order passed in compliance with the direction of th....
Contempt proceedings cannot substitute for enforcement of binding court decisions; non-compliance must involve clear disregard of valid orders. The exercise of contempt jurisdiction is limited to ens....
Contempt jurisdiction must adhere to strict procedural norms and should not incorporate issues merits of the underlying dispute, as confirmed by established legal precedents.
The main legal point established in the judgment is that the Contempt Court must be conscious that it is not possessed of the powers of other corrective jurisdictions like review or appeal against th....
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