Contempt of Courts Act, 1971 – Contempt Proceedings – Scope of – Writ petitions filed by respondents – By order dtd. 17.5.12, High Court passed direction to frame guidelines and till the guidelines were framed, there was a direction to maintain status quo as on the date of the judgment – Guidelines framed – Respondents filed contempt petition alleging that the said guidelines were in violation of judgment dtd. 17.5.2012 – High Court held that the guidelines framed were in violation of the judgment and issued further orders as well – Held: There was no violation of the status quo order granted on 17.5.2012 – Direction to maintain status quo was only till framing of guidelines – Once the guidelines were framed, the life of the interim order to maintain status quo also expired and thereafter, the field was to be governed by the new guidelines – In contempt jurisdiction, the Court cannot expand the scope of the judgment which is alleged to have been violated – Impugned order is set aside.
Disposing of the appeals, the Court
HELD: 1.1 It is very difficult to appreciate the stand of the High Court that there was violation of the status quo order granted on 17.05.2012. The direction to maintain status quo was only till framing of guidelines. Once the guidelines were framed, the life of the interim order to maintain status quo also expired and thereafter, the field was to be governed by the new guidelines framed and notified on 21.05.2014. If the respondents are, in any way, aggrieved by the guidelines, it is for them to pursue appropriate remedy but not proceedings for contempt. In contempt jurisdiction, the Court cannot expand the scope of the Judgment which is alleged to have been violated. The Court’s jurisdiction in contempt proceedings is to see whether there is willful disobedience of any direction or a contumacious attempt otherwise to circumvent the Judgment. Sans that the rest should be left to the aggrieved party to pursue the matters in other appropriate proceedings. [Para 7][1007-C-E]
As published in the Supreme Court Reports, Supreme Court of India. Text from the Indian Supreme Court Judgments open data set (Dattam Labs), CC BY 4.0.
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