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2026 Supreme(Online)(Tel) 12166

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
C. V. Bhaskar Reddy, J
Nawab Mohd Yousufuddin Khan – Appellant
Versus
Koppula Venkat Reddy – Respondent
CONTEMPT CASE No.1563 of 2025



Compliance with a court order must be substantive, effective, and in accordance with the true spirit of the mandate. Mechanical compliance that ignores the scope of a remand or relies on already invalidated proceedings constitutes willful disobedience and warrants action under contempt jurisdiction.

Headnote:(A) Contempt of Courts Act, 1971 - Sections 10 to 12 - Constitution of India - Article 215 - Contempt jurisdiction - Scope and purpose - Aimed at ensuring that orders of the court are obeyed in both letter and spirit - Mere formal or mechanical compliance without proper application of mind does not amount to compliance in the eye of law. (Paras 14, 15)

(B) Administrative Law - Quasi-judicial orders - Duty to provide reasons - When a remand order directs fresh adjudication, the authority must apply its mind to evidence and arguments, failing which the order suffers from non-application of mind and arbitrariness - An authority cannot sit in appeal over the orders of a court by ignoring binding judicial pronouncements under the guise of compliance. (Paras 10, 11, 13)

Facts of the case:
A petition was filed seeking to punish the respondent for willful disobedience of a court order directing the respondent to pass a fresh order regarding land claims following a remand order from a tribunal. The respondent failed to adhere to the stipulated time frame and subsequently passed an order relying on earlier proceedings which had been set aside. The respondent's action was challenged as an attempt to avoid contempt proceedings through a non-substantive, mechanical, and self-contradictory order that failed to address the core issues and documentary evidence.

Findings of Court:
The court observed that the respondent failed to comply with the directions in true letter and spirit. The order passed by the respondent was found to be based on an incorrect premise, lacking independent application of mind, and ignoring previous findings that had settled the legal status of the land. The court concluded that the purported compliance was a mere formality aimed at avoiding the consequences of contempt.

Issues: Whether the respondent's action in passing a fresh order constituted actual compliance with the court's direction, and whether the respondent is liable for willful disobedience under the Contempt of Courts Act, 1971.

Ratio Decidendi: Compliance of a judicial order must be real, effective, and in accordance with the spirit of the directions, not a mere eyewash. An order passed by a quasi-judicial authority that ignores the specific scope of a remand and relies on discredited past proceedings demonstrates an absence of bona fide effort, thereby establishing willful and deliberate disobedience.

Result: Contempt case allowed; respondent sentenced to one month imprisonment and a fine of Rs. 2,000; impugned administrative proceedings set aside, and the matter entrusted to another authority for fresh adjudication.

Table of Content
1. failure to comply with court-ordered timelines for adjudication. (Para 1 , 2 , 3 , 4)
2. parties' contentions regarding whether delayed administrative orders constitute bona fide compliance. (Para 5 , 6 , 7)
3. requirement for meaningful, non-arbitrary application of mind in quasi-judicial compliance. (Para 8 , 9 , 10 , 11 , 12 , 13)
4. standard of contempt for public authorities failing to implement court directions in spirit. (Para 14 , 15)
5. court's power to set aside invalid administrative orders and impose punitive measures for contempt. (Para 16 , 17)

ORDER

This Contempt Case is filed by the petitioner seeking to punish the respondent/contemnor (Revenue Divisional Officer) under Sections 10 to 12 of the Contempt of Courts Act, 1971 for wilfully, wantonly and intentionally not obeying the order dated 18.02.2025 passed by this Court in Writ Petition No.4744 of 2025.

2. The petitioner herein has filed Writ Petition No.4744 of 2025 seeking a direction to the respondent to pass orders in C.C.Nos.W/80/75 and W/92/75 in respect of land admeasuring Ac.74.97 cents in Sy.Nos.174 to 176, 178, 182, 183 and 154 situated at Peddashapur Village, Shamshabad Mandal, Ranga Reddy District. It is the case of the petitioner that the subject lands originally belonged to his predecessor and that the matter was remanded by the Land Reforms Appellate Tribunal-cum-II Additional District Judge, Ranga Reddy District in L.R.A.No.10 of 2012 dated 04.04.2017 for fresh adjudication. Despite completion of hearing and reserving the matter for orders on 02.11.2024, no orders were passed by the respondent, which constrained the petitioner to approach this Court by filing the aforesaid writ petition.

3. This Court vide order dated 18.02.2025 disposed of W.P.No.4744 of 2025 directing the respondent No.3 therein/respondent herein to pass orders in C.C.Nos.W/80/75 and W/92/75 strictly in accordance with law, as expeditiously as possible, preferably, within a period of six (06) weeks from the date of receipt of a copy of the order and to communicate the decision to the petitioner.

4. It is the case of the petitioner that despite the aforesaid direction, the respondent failed to pass orders within the stipulated time and therefore, the present Contempt Case is filed.

5. The learned counsel for the petitioner submits that the respondent has willfully and deliberately disobeyed the orders passed by this Court in W.P.No.4744 of 2025. It is contended that though this Court, vide order dated 18.02.2025, directed the respondent to pass orders within a period of six weeks, the respondent failed to adhere to the said time frame and did not pass any orders even long after expiry of the stipulated period. It is further submitted that the petitioner, having no other alternative, made a representation dated 25.03.2025 bringing to the notice of the respondent the directions issued by this Court and requesting early compliance, but the same did not evoke any response. It is contended that the conduct of the respondent clearly demonstrates lack of respect to the orders of this Court and amounts to intentional and willful disobedience. The learned counsel would further submit that the proceedings dated 24.02.2026, which are now relied upon by the respondent, were passed only after initiation of contempt proceedings and issuance of notice in Form-I by this Court, and therefore, the same cannot be treated as bona fide compliance. It is contended that the said proceedings dated 24.02.2026 was issued only to escape the consequences of contempt, without examining the matter in proper perspective. The learned counsel contended that the respondent failed to consider the remand order passed in L.A.R.No.10 of 2012 dated 04.04.2017, wherein the earlier orders were set aside and the matter was remitted for fresh adjudication. It is further contended that the respondent ignored the documentary evidence placed by the petitioner, including the allotment of the subject lands in

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