Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(P&H) 77826

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
Nidhi Gupta, J
Daljit Singh – Appellant
Versus
Manzoor Hussain – Respondent
COCP-42-2023

Advocates:
For the Appellants/Petitioners: Manish Dadwal
For the Respondents: Saurav Verma, Manmeet S. Teji, Aashika Jain, Balwant Singh, Pawan Kumar, Mandeep Singh, Taranjit Singh

A contempt petition for non-compliance with a status quo order is not maintainable when the opposing party proves prior continuous possession and lawful acquisition of the subject property, and the petitioner fails to controvert these material facts.

Headnote:(A) Contempt of Courts Act, 1971 - Disobedience of Court order - Land Acquisition Act, 1894 - Sections 4, 6, 9(3), 10, 11, 11-A, 17(1) - Acquisition proceedings for Kandi Canal - Allegation of non-payment of compensation and violation of status quo - State records revealed land was acquired in 1989-91, compensation was deposited, and possession was vested with the State - Petitioners’ predecessor had previously filed writ petitions challenging acquisition which were dismissed - No evidence of wilful disobedience of court orders found as land was already in possession of State prior to status quo order. (Paras 6, 7, 16, 17, 18, 21)

Facts of the case:
The petitioners filed a contempt petition alleging violation of an order dated 08.08.2014, claiming that the State had failed to pay compensation for acquired land and had violated a status quo order concerning possession by initiating construction work in 2022. The respondent State contested this, providing evidence that the land was acquired in 1989-91, compensation was deposited, and possession was taken by the government long before the court order.

Findings of Court:
The court noted that the petitioners failed to dispute the records presented by the State, which confirmed the acquisition, payment of compensation, and long-standing government possession. There was no violation of the status quo as the State was in possession of the land since 1991.

Issues: Whether the respondents committed wilful disobedience of the status quo order regarding land possession and failed to pay due compensation.

Ratio Decidendi: As the land was legally acquired and possession was taken by the State prior to the court's status quo order, and the allegations of non-payment were contradicted by records, no prima facie case for contempt was established.

Result: Contempt Petition dismissed as withdrawn.

Table of Content
1. procedural history and grievances regarding alleged contempt of status quo orders. (Para 1 , 2 , 3 , 4 , 5 , 6)
2. arguments concerning land acquisition, possession, and validity of contempt petition. (Para 7 , 8 , 9 , 10 , 11 , 12 , 13)
3. court findings on lack of disobedience and dismissal of contempt petition. (Para 14 , 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24)

101+201

NIDHI GUPTA, J.

CM-7495-CII-2026

This is an application under Section 151 CPC on behalf of the applicants/petitioners to place on record reply to the affidavit dated 17.3.2026 filed by respondent No.3.

After going through the contents of the application, which is supported by affidavit of applicant/petitioner No.1, the same is allowed subject to all just exceptions and reply to the affidavit filed by the respondent No.3 is taken on record.

CM-8012-CII-2026

This is an application under Section 151 CPC for exemption from personal appearance of Krishan Kumar, Principal Secretary to Government of Punjab, Department of Water Resources in support of application under Section 151 CPC for exemption from personal appearance before this Court for 18.04.2026.

After going through the contents of the application, the same is allowed subject to all just exceptions.

MAIN CASE

Present Contempt Petition has been filed by the petitioners alleging violation of the order dated 08.08.2014 passed by a Division Bench of this Court in CWP-10555-2014 titled as “Daljit Singh & Others Vs. State of Punjab & Others”, whereby it was directed as follows:-

“CM No.8424 of 2014

For the reasons recorded in the application, the same is allowed subject to all just exceptions and the documents at Annexures P11 and P12 are taken on record.

CM stands disposed of.

CWP No.10555 of 2014

The land of the petitioners was acquired by the State of Punjab. Although compensation was determined but it is the case of the petitioners that neither the compensation has been deposited before the competent court nor the actual physical possession has been taken and, thus, the acquisition proceedings have lapsed in view of Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013.

Notice of motion.

On our asking, Ms. Manisha Gandhi, Additional Advocate General, Punjab accepts notice on behalf of the State. Let three copies of the writ petition be supplied to learned State counsel during the course of the day.

Keeping in view the above contentions raised by the counsel for the petitioners, we direct the State of Punjab to find out as to whether the compensation has been deposited in competent court and/or the actual physical possession has been taken or not.

Post on 05.09.2014.

In the meantime, there shall be status quo as it exists today.”

2. On the last date of hearing i.e. 27.03.2026, following order was passed:-

“Prayer in the present application (CM-16209-CII-2025) is for placing on record additional affidavit of the applicant-petitioner No.1- Daljit Singh alongwith true translated copy of Roznamcha as Annexure P- 3) and exemption from filing the certified/typed copy thereof.

Notice in the application.

Learned counsel for the State accepts notice of the application.

Learned counsel for the respondents has placed on record the affidavit dated 17.03.2026 of Ms. Aashika Jain, Deputy Commissioner, Hoshiarpur (respondent No.3), which is taken on record. A copy thereof has been supplied to learned counsel for the applicants-petitioners.

Learned counsel for the respondents submits that the document dated 28.03.1989 (Annexure R-1) is a Rapat Roznamcha.

Per contra, learned counsel for the petitioners seeks time to file a reply to the said affidavit and submits that the document in question is not a Rapat Roznamcha, but pertains to a Munadi allegedly conducted by the respondents under Section 4 read with Section 17(1) of the Land Acquisition Act, indicating the proposed acquisition of the land of the petitioners. It is further s

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2026 Supreme(Online)(P&H) 77826

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARHNidhi Gupta, JDaljit Singh – AppellantVersusManzoor Hussain – RespondentCOCP-42-2023

A contempt petition for non-compliance with a status quo order is not maintainable when the opposing party proves prior continuous possession and lawful acquisition of the subject property, and the petitioner fails to controvert these material facts.

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
Nidhi Gupta, J
Daljit Singh – Appellant
Versus
Manzoor Hussain – Respondent
COCP-42-2023