M/S. R.N. Forging PVT. LTD. vs. Rajendra Kumar

Held

The Court held that the contempt petitions have become infructuous. The reasoning provided by the respondents, and accepted by the Court, was that the connected writ petitions had been disposed of by a Division Bench of the High Court through orders dated October 31, 2023, and September 27, 2023. As the contempt petitions were filed alleging non-compliance with an interim order passed in those writ petitions, their disposal rendered the contempt proceedings moot. The Court did not delve into the merits of the alleged non-compliance with the interim order. The ratio decidendi is that once the main proceedings in which an interim order was passed are disposed of, contempt proceedings based on the alleged violation of that interim order become infructuous. The operative direction was to dispose of the contempt petitions as having become infructuous and discharge the notices.

Facts

The petitioners, M/s. R.n. Forging Pvt. Ltd. and M/s. Lupin Forging Pvt. Ltd., filed contempt petitions (No. 740/2020 and No. 739/2020 respectively) alleging non-compliance with an interim order dated April 11, 2019, passed by the High Court. The respondents are officials from the Director General of Goods and Services Tax Intelligence (DGGI), Jaipur Regional Unit. The contempt petitions were filed in connection with earlier writ petitions (No. 5437/2019 and No. 5589/2019). The contempt proceedings were initiated due to the alleged failure of the respondents to adhere to the interim directions issued by the Court in the writ petitions.

Key Issues

1. Whether the contempt petitions have become infructuous in light of subsequent orders passed by the Division Bench of the High Court disposing of the connected writ petitions? Petitioner's Argument: The petitioner would argue that the contempt petitions are valid and subsisting as the alleged non-compliance with the interim order has not been rectified, and the contempt proceedings are independent of the disposal of the main writ petitions. They would likely contend that the contempt action is to uphold the majesty of the court's orders. Respondent's Argument: The respondents argued that the contempt petitions have become infructuous. They submitted that the Division Bench of the High Court, vide orders dated October 31, 2023, and September 27, 2023, has disposed of the connected writ petitions. Therefore, the basis for the contempt proceedings, which stemmed from the interim order in those writ petitions, no longer exists, rendering the contempt petitions moot.