1. Appeal under Section 19(1)(a) of the Contempt of Courts Act, 1971 against order in contempt proceedings. (Para 6 )
2026 Supreme(Online)(Del) 18634
IN THE HIGH COURT OF DELHI AT NEW DELHI
Prathiba M. Singh, Dinesh Bhatt, JJ
Bharat Singh Rawat – Appellant
Versus
Poonam Singh Rawat – Respondent
CONT.APP.(C) 22/2026
For the Appellants/Petitioners: Gayatri Puri, Saksham Sethi, Siddhant Sahil
For the Respondents: None
Appeals under Section 19 of the Contempt of Courts Act, 1971, are maintainable only against orders that impose punishment for contempt, and not against orders that merely direct compliance or initiate proceedings.
Headnote:(A) Contempt of Courts Act, 1971 - Section 19 - Maintainability of Appeal - An appeal under Section 19 is maintainable only against an order or decision passed in exercise of jurisdiction to punish for contempt, specifically an order imposing punishment. An order merely directing compliance with a previous order or payment of arrears is not appealable under this section. (Para 12, 14)
Issues: Whether an appeal under Section 19 of the Contempt of Courts Act, 1971 is maintainable against an order directing the payment of arrears without imposing punishment for contempt.
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Table of Contents
2. Appellant argued proceedings should be clubbed due to multiple cases from one matrimonial dispute. (Para 10 )
3. Impugned order only directs compliance to pay arrears and does not impose punishment for contempt. (Para 11 , 14 )
4. Appeal under Section 19 lies only against orders punishing for contempt, not directions on merits. (Para 12 , 14 )
5. Appeal disposed as not maintainable; liberty granted to file application for clubbing before single judge. (Para 15 , 16 )
6. Is an appeal under Section 19 of the Contempt of Courts Act maintainable against an order that does not punish for contempt?
No. An appeal under Section 19 is maintainable only against an order imposing punishment for contempt, not against directions on merits of the dispute. (Para 12 , 14 )
7. What types of orders in contempt proceedings are not appealable under Section 19 of the Contempt of Courts Act?
Orders declining to initiate, initiating, dropping, or acquitting/exonerating the contemnor are not appealable under Section 19, though may be challenged under Article 136. (Para 12 )
8. Can an appellate court club multiple cases arising from the same matrimonial dispute in a contempt appeal?
No. The appellate court in a contempt appeal does not decide the clubbing issue; the party may file an appropriate application before the single judge. (Para 15 )
1. This hearing has been done through hybrid mode.
CRL.M.A. 65365/2026 (exemption)
2. Allowed, subject to all just exceptions. Application is disposed of.
CRL.M.A. 65364/2026 (for condonation of delay of 08 days in filing appeal)
3. This is an application seeking condonation of delay of 8 days in filing the appeal.
4. For the reasons mentioned therein, delay in filing the appeal is condoned.
5. Application is allowed and disposed of.
CONT.APP.(C) 22/2026 & CM APPL. 65363/2026 ( ex-parte-stay)
6. The present appeal has been filed by the Appellant under Section 19(1)(a) of the Contempt of Courts Act, 1971, inter alia, assailing the impugned order dated 27th July, 2026 passed by the ld. Single Judge in Cont. Cas. (C) 1295/2026 titled ‘Poonam Singh Rawat and Ors. v. Bharat Singh Rawat’.
7. The grievance of the Respondent in the Cont. Cas. (C) 1295/2026 was that the order of the Family Court-02, East District, Karkardooma Courts, Delhi, in respect of the maintenance to be paid to the Respondent, is not being complied with by the Appellant.
8. Vide the impugned order, ld. Single Judge has held as under:
“17. He further submits that there are only 33 cases, which are pending between the parties, and not 123.
18. He further submits that since the petitioners have already filed execution petitions, this contempt petition ought not to be entertained.
19. He submits that if the present petition is entertained, then he shall also file cases before this Court, and this Court would be flooded with cases.
20. This Court has taken a very serious view of the aforesaid statement made by the respondent, who is a practising lawyer and appearing in person before this Court.
21. The respondent has apologized to this Court.
22. This Court notes the submission made by learned counsel appearing for the petitioners that the respondent had been paying an amount of Rs. 10,000/~ per month, in comparison to the amount of Rs. 20,000/~ per month, which is due and payable. Thus, as on date, an amount of Rs.5,60,000/- is due and payable by the respondent to the petitioners.
23. The details as given in the petition, is reproduced as under:
“xxx xxx xxx pp.That the total calculation of the arrears of maintenance is given herein below:-
i) Domestic ~ Violence Maintenance Order dated 16.03.2019 — Rs.10000/- was granted as ad-interim maintenance.
ii) Maintenance Order u/s 125 CrpC Petition dated 16.042024 - maintenance granted Rs.20000/- from the date of filing i.e. 25.6.21.
iii) Total amount paid from 25.6.21 to till dat XXX s.180000/-
iv) Adjustment of amount to be paid to husband Rs.460000/-
v) Total arrears Rs.1200000/- minus 180000 + 460000 = 560000/-
vi) Total arrears is Rs.5600000/- xxx xxx xxxx”
24. Accordingly, the respondent is granted liberty to file response to the aforesaid petition.
25. He is further directed to comply with the orders of this Court and pay the due arrears as aforesaid.
26. Let the needful be done, before the next date of hearing.”
9. A perusal of the impugned order shows that there are a large number of cases ongoing between the parties, including two contempt petitions.
10. Ld. Counsel for the Appellant submits that the proceedings deserve to be clubbed as the Appellant is being forced to defend and prosecute various cases, due to one matrimonial dispute. It is stated that the Appellant and Respondent are husband and wife, and are stated to be practising lawyers.
11. The Court has considered the matter. The observation of the ld. Single Judge in the impugned order is to only comply with the order and pay the arrears.
12. Furthermore, in view of the decision of the Supreme Court in Midnapore Peoples' Coop. Bank Ltd. v. Chunilal Nanda , (2006) 5 SCC 399 the present appeal is not maintainable. In ‘Midnapore Peoples’ Coop. Bank Ltd. v. Chunilal Nanda (2006) 5 SCC 399, the Court has clearly held that appeals under Section 19 of the Contempt of Courts Act, 1971 would be maintainable only in re