Disgorging Of Benefits Through 'Purging' Of Contempt Instils Public Confidence In Rule Of Law: Telangana High Court

Update: 2025-07-22 05:18 GMT
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The Telangana High Court Division Bench, comprising of Justices Moushumi Bhattacharya and B.R. Madhusudhan Rao has observed that the Court's power to preserve its magnanimity by ensuring compliance of its order is not a self-serving mechanism but to instill public confidence in the proper administration of justice. The rationale behind the contempt jurisdiction is to uphold the dignity of...

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The Telangana High Court Division Bench, comprising of Justices Moushumi Bhattacharya and B.R. Madhusudhan Rao has observed that the Court's power to preserve its magnanimity by ensuring compliance of its order is not a self-serving mechanism but to instill public confidence in the proper administration of justice. 

The rationale behind the contempt jurisdiction is to uphold the dignity of the Court of law, since the image of the Court in the mind of the people cannot be tainted, the court said. 

Factual Matrix:

A mother of three children (“Respondent No. 1/alleged contemnor”) had file a Writ of Habeas Corpus seeking directions for the State Authorities to produce her children before the Court. She had also filed an I.A. for visitation rights. The petitioner in this case, and Respondent No. 5 in the Writ Petition, filed a Guardianship and Wards Original Petition (“GWOP”) for permanent custody of the three children. The Writ Petition and I.A. for visitation rights filed by the Respondent No.1/alleged contemnor was disposed of vide order dated 04.03.2025.

The Court allowed the Respondent No.1/alleged contemnor to visit the three minor children on the weekends. It was her responsibility to pick and drop the children to the residence of the Respondent No. 5/Contempt Petitioner. The said writ petition was disposed off on the ground that the writ petitioner/ alleged contemnor can contest the proceedings initiated in the family court by Respondent No. 5/Contempt Petitioner.

On 21.06.2025 the Respondent No. 1/alleged contemnor took the children from the contempt petitioner's house, to Bhopal with her. A formal complaint was lodged by he contempt petitioner with the Jubilee Hill Police Station on the same day. Meanwhile the GWOP filed the contempt petitioner before the Family Court in Hyderabad is pending.

Submissions:

The counsel for the Respondent submitted that the contempt petitioner is not entitled to seek the return of the three minor children and to produce them in Court. This relief would travelled beyond the directions contained in the order dated 04.03.2025. Therefore, the Contempt Case is not maintainable.

Court's Observation:
The bench observed that the the Writ Petition filed by the alleged contemnor was disposed on the ground that a GWOP had already been filed by the contempt petitioner for permanent custody of the minor children. The alleged contemnor was granted the liberty to the contest the custody of the children. The bench directed the the alleged contemnor to return the three children to the contempt petitioner, reiterating that such direction is in line with the requirement of purging the act of contempt.
It was further observed that the concept of 'Purguing' has been recognised as an essential facet of contempt jurisdiction where the contemnor is directed to make reparation of the wrongdoing. The Supreme Court in Pravin C. Shah v. K.A. Mohd. Ali (2001) held that the act of amending the wrong is borne out of equity where the contumacious conduct must be cleaned by the contemnor. The process of purguing also requires the contemnor to relinquish the benefits secured as a result of their contemptuous act. The Supreme Court in State Bank of India v. Dr. V. Vijay Mallya (2022) reiterated that the magnanimity of law warrants appropriate directions to be issued to ensure that the advantage secures by the contemptuous act is completely nullified. The purge may also require the reversal of the transaction in question.
The Supreme Court in Supreme Court Bar Association v. Union of India (1998) prevented the contemnor advocate form appearing before the Court till he purged himself off the contempt. The Delhi High Court in D.K.C v. K.C (2016)directed the father to return the minor child to the mother. The observed that the difficulty in implementing an order of the Court cannot justify its non-implementation.
The purpose of the contempt jurisdiction is to uphold the dignity of the Court of law. The Court's image in the mind of the common people cannot be tainted. Furthermore, the object of the discipline enforced by the Court in contempt matters is to prevent undue interference with the administration of justice.
The bench lastly observed that the act of contempt on the part of the Respondent No. 1/alleged contemnor is willful and deliberate. The Respondent No.1/alleged contemnor has not tendered any apology, and the Court is not left with any other option but to direct that the status of the children be restored to the agreement in place vide order 04.03.2025.

Case Name: Shujahat Hussain v. Sidra Hussain Shujahat

Case Title: CONTEMPT CASE No. 1388 of 2025

Counsel for the Petitioner: Mr. Sharad Sanghi Jubin Prasad, Advocate

Counsel for the Respondent: Mr. Shaik Muhammad Abed, Advocate

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