1. State authorities repeatedly interfered with petitioner's private land possession despite multiple judicial declarations and undertakings confirming the petitioner's title and prohibiting such encroachment. (Para 5 , 6 , 7 , 8 , 9 , 15 , 16 , 17 , 18 , 19 , 20 , 21 , 30 , 34 )
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2026 Supreme(Telangana) 965
HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
Anil Kumar Jukanti, J.
M/s. Shanta Sriram Constructions Private Limited - Petitioner
Versus
AV Ranganath - Respondent
Contempt Case Nos.3482 and 3483 of 2026
Decided On : 27-07-2026
Important Points
Willful disobedience of a court's clear order or undertaking by a public official undermines the rule of law and the majesty of courts, justifying punitive action and removal from office to ensure judicial mandates are respected over arbitrary administrative power.
Subject
Constitutional Law - Contempt of Court
Act Referred
Headnote
(A) Constitution of India - Article 215 and Article 300A; Contempt of Court Rules - Rule 27; Code of Civil Procedure, 1908 - Order VII Rule 11(d) - Power to punish for contempt - Willful disobedience of an undertaking given to the Court - An apology must be offered at the earliest opportunity and in good grace to be accepted; if offered only when the contemnor finds that the Court is going to impose punishment, it ceases to be an apology and is liable to be rejected (Paras 52-53).
(B) Contempt of Court - Nature and scope - Willful disobedience signifies an act or omission done voluntarily with specific intent to fail to do something the law requires, typically with bad purpose or evil intent (Para 59) - Contempt jurisdiction exists to preserve the majesty and sanctity of the law and to ensure that judicial decisions command respect and compliance to prevent anarchy (Paras 61-63).
Facts of the case:
The petitioner's title to a parcel of land was upheld through multiple court proceedings, and a subsequent civil suit filed by the state was rejected as being barred by limitation. In a prior contempt proceeding, the respondent gave a formal undertaking to the court that its officials and staff would not enter the subject premises. Despite this undertaking and specific restraining orders, the respondent entered the property with machinery and police personnel, demolished temporary structures, and attempted to fence the area without serving any notice to the petitioner.
Findings of Court:
The court found that the respondent willfully violated the undertaking given to the court. The apology tendered in a subsequent affidavit was rejected because it was not offered on the respondent's own volition but was a consequence of the court expressing its displeasure. The respondent's actions were deemed a flagrant violation of the rule of law and a deliberate attempt to overreach the judiciary.
Issues: Whether the act of entering a private property and demolishing structures in breach of a formal undertaking given to the Court constitutes willful contempt of court.
Ratio Decidendi: Where an order of a competent court is clear and unambiguous, disobedience of such an order or breach of an undertaking amounts to contempt. Such conduct undermines the administration of justice and the rule of law. Public officials are not above the law, and the majesty of the court must be upheld by ensuring that judicial mandates are not treated with laxity, particularly when an official displays contumacious conduct.
Result: The respondent is to be relieved from the post of Commissioner in the interest of justice and to uphold the rule of law; the Chief Secretary of the State Government is requested to find a suitable replacement. Contempt cases closed in these terms.
(B) Contempt of Court - Nature and scope - Willful disobedience signifies an act or omission done voluntarily with specific intent to fail to do something the law requires, typically with bad purpose or evil intent (Para 59) - Contempt jurisdiction exists to preserve the majesty and sanctity of the law and to ensure that judicial decisions command respect and compliance to prevent anarchy (Paras 61-63).
Facts of the case:
The petitioner's title to a parcel of land was upheld through multiple court proceedings, and a subsequent civil suit filed by the state was rejected as being barred by limitation. In a prior contempt proceeding, the respondent gave a formal undertaking to the court that its officials and staff would not enter the subject premises. Despite this undertaking and specific restraining orders, the respondent entered the property with machinery and police personnel, demolished temporary structures, and attempted to fence the area without serving any notice to the petitioner.
Findings of Court:
The court found that the respondent willfully violated the undertaking given to the court. The apology tendered in a subsequent affidavit was rejected because it was not offered on the respondent's own volition but was a consequence of the court expressing its displeasure. The respondent's actions were deemed a flagrant violation of the rule of law and a deliberate attempt to overreach the judiciary.
Issues: Whether the act of entering a private property and demolishing structures in breach of a formal undertaking given to the Court constitutes willful contempt of court.
Ratio Decidendi: Where an order of a competent court is clear and unambiguous, disobedience of such an order or breach of an undertaking amounts to contempt. Such conduct undermines the administration of justice and the rule of law. Public officials are not above the law, and the majesty of the court must be upheld by ensuring that judicial mandates are not treated with laxity, particularly when an official displays contumacious conduct.
Result: The respondent is to be relieved from the post of Commissioner in the interest of justice and to uphold the rule of law; the Chief Secretary of the State Government is requested to find a suitable replacement. Contempt cases closed in these terms.
Legal Category Hierarchy
Table of Contents
2. Petitioner alleges wilful disobedience by state authorities of court orders and undertakings, while respondents contend they acted under statutory mandates to protect government assets. (Para 42 , 43 , 44 , 45 , 46 , 47 )
3. The deliberate violation of court orders and undertakings by state authorities undermines the rule of law and the majesty of the judiciary, warranting strict judicial intervention. (Para 1 , 2 , 3 , 4 , 14 , 54 , 55 , 56 , 57 , 69 , 70 , 71 , 72 , 80 , 81 )
4. State authorities must respect judicial orders as part of the rule of law; wilful defiance of court undertakings constitutes contumacious conduct, regardless of claimed statutory powers. (Para 58 , 59 , 60 , 61 , 62 , 63 )
5. The court closed the contempt proceedings after finding wilful disobedience and ordered the immediate relief of the respondent officer from his current official assignment. (Para 84 , 85 )
6. What constitutes wilful disobedience in the context of contempt jurisdiction?
Wilful disobedience signifies an act done voluntarily with specific intent to disregard a court order or fail to perform a required legal act, manifesting evil intent or bad motive to frustrate judicial administration. (Para 59 , 60 , 62 )
7. Can contempt of court be found in the absence of an explicit prohibitory order?
Yes, contempt exists beyond direct disobedience of specific orders. Deliberate conduct aimed at frustrating court proceedings, nullifying decisions, or undermining judicial authority can constitute contempt even without a specific mandate or prohibitory order. (Para 62 )
8. How should a court handle a belated apology in contempt proceedings?
An apology must be offered at the earliest opportunity and in good grace. An apology offered only after the court expresses displeasure or indicates intent to punish is shorn of penitence and should be rejected as a cringing act. (Para 52 , 53 )
ORDER :
ANIL KUMAR JUKANTI, J.
It is an apt case to refer to the story of Greek mythology, where a serpentine water monster, by name, ‘Hydra’, a symbol of resilience and regeneration, posed challenges that seem insurmountable to any, who tried to conquer it. This Hydra of Greek mythology is traditionally depicted as a gargantuan serpent with numerous heads. The distinctive and daunting trait of remarkable regenerative ability made the Hydra (of Greek mythology) nearly invincible to those, who attempted to conquer it, but was ultimately slayed.
2. I hope HYDRAA i.e., Hyderabad Disaster Response and Assets Protection Agency (for short, ‘the HYDRAA’) is not under the same impression that it is invincible.
3. If Courts were to permit HYDRAA to overpower/overtake every formidable adversary i.e., citizens of State, by not adhering to Rule of Law, then it would sound a death knell to Rule of Law.
4. Hope, HYDRAA will learn that acts in defiance to Rule of Law will not be upheld and such acts will be dealt sternly by Courts of Law, as the Hydra in Greek mythology was dealt with by Hercules.
5. Case History:
This case has a long history. Petitioner in these contempt cases preferred a Writ Petition bearing No.5049 of 2016, subject matter in the writ petition pertained to an extent of Acs.40.00 of land in Survey Nos.1 and 2 of Lothukunta Village, Malkajgiri Mandal, Ranga Reddy District. Writ petition was adjudicated along with C.R.P.No.406 of 2021, the respondent - State suffered an order.
6. A Writ Appeal bearing No.150 of 2021 was preferred by the State against the order of learned Single Judge. In the Writ Appeal, liberty was sought to approach Civil Court for filing a suit, Writ Appeal was disposed of granting liberty.
7. O.S.No.55 of 2021 was preferred by the State before a competent Civil Court. An application was filed under Order VII Rule 11 (d) of Code of Civil Procedure, 1908 (for short ‘C.P.C.’) by the petitioner herein, it was allowed by the I Additional Chief Judge, City Civil Court at Secunderabad.
8. A City Civil Court Appeal bearing No.49 of 2022 was preferred by the State against the judgment and decree of the trial Court, a Division Bench of this Court by its judgment dated 07.10.2025 dismissed the appeal preferred by the State.
9. Judgment of Division Bench attained finality, State did not challenge the judgment of Division Bench till date. Title claimed in respect of subject property by petitioner is upheld by Courts and remains to be of petitioner till date.
10. Two contempt cases were filed prior to the present contempt case(s). 1st contempt case(s) was closed on an assurance that the respondents in contempt case(s) would comply with the Court’s order dated 08.03.2021 in W.P.No.5049 of 2016.
11. In the 2nd contempt case(s), an undertaking was given to the Court and Court restrained respondent and its staff not to enter the subject premises.
12. On HYDRAA:
Birth of HYDRAA is traceable to G.O.Ms.No.99, dated 19.07.2024, as a separate department (Head of Department) under Municipal Administration and Urban Development. Commissioner, HYDRAA (rank of Secretary) is to function under overall supervision and guidance of Principal Secretary to Government, Municipal Administration and Urban Development Department.
13. Functions and responsibilities of HYDRAA are spelled out in G.O.Ms.No.99, dated 19.07.2024. By another G.O.Ms.No.191, Municipal Administration & Urban Development (GHMC.I) Department, dated 16.10.2024, the Commissioner, HYDRAA (i.e., the contemnor/ respondent herein) is empowered to protect the Public Assets like roads, drains, public streets, water bodies, open spaces, public parks, etc., belonging to the GHMC or to the State Government, within the jurisdiction of GHMC, so as to preserve them from any kind of illegal encroachments, for the purpose of disaster management and protection of public assets.
14. No doubt, the objective of the G.Os., issued seems to be laudable, but any overreach by the authorities in a zeal to protec
