Doctrine of merger does not apply to contempt proceedings when Single Judge order confirmed by Division Bench.

(By G.R.SWAMINATHAN, J.)

Heard the learned counsel for the petitioner.

2.The petitioner alleges that the order dated 15.09.2025 passed by the Hon'ble Division Bench in W.A.(MD)No.1297 of 2022 has not been complied with and hence, this contempt petition has been filed.

3.It is seen that the Hon'ble Division Bench had confirmed the order of the learned Single Judge passed in W.P.(MD)No.4103 of 2014 on 19.05.2022. The Hon'ble Supreme Court in a recent decision reported in 2026 INSC 204 (United Labour Federation vs Gagandeep Singh Bedi) has held that the doctrine of merger will not apply to contempt proceedings where the order of the learned Single Judge has been confirmed by the Division Bench. Therefore, we close the present contempt petition and grant liberty to the petitioner to file a fresh contempt petition. The same shall be listed before the learned Single Judge concerned.