M/S. Lupin Forging PVT. LTD. vs. Rajendra Kumar

Held

The Court held that the contempt petitions have become infructuous. The reasoning provided by the respondents' counsel was accepted. It was submitted that the main writ petitions, in relation to which the interim order was passed, have since been disposed of by a Division Bench of the High Court on October 31, 2023, and September 27, 2023. Consequently, the contempt petitions, which alleged non-compliance with the interim order in those writ petitions, have lost their purpose and are no longer sustainable. The Court found that the subsequent disposal of the writ petitions rendered the contempt proceedings moot. The operative direction was to dispose of the contempt petitions as having become infructuous and to discharge the notices issued.

Facts

The petitioners, M/s. R.n. Forging Pvt. Ltd. and M/s. Lupin Forging Pvt. Ltd., filed contempt petitions 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 relation to the underlying writ petitions, SB Writ Petition No. 5437/2019 and SB Civil Writ Petition No. 5589/2019. The contempt proceedings were initiated due to the alleged failure of the respondents to adhere to the court's interim directions.

Key Issues

1. Whether the contempt petitions have become infructuous in light of the subsequent disposal of the main writ petitions by a Division Bench of this Court? Petitioner's Argument: The petitioner would contend that the contempt petitions are maintainable and that the respondents have willfully disobeyed the interim order of the court. They would likely argue that the disposal of the writ petitions does not automatically render the contempt proceedings void, especially if the contempt pertains to actions taken prior to the disposal or if the contemptuous conduct continues. Respondent's Argument: The respondents argued that the contempt petitions have become infructuous. They submitted that the Division Bench of this Court, vide orders dated October 31, 2023, and September 27, 2023, has disposed of the 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.