Appeal under Section 19 of Contempt of Courts Act is only maintainable against orders imposing punishment.

The Appellants, the mother and sister of a husband (Respondent No. 2), challenged an order dated March 12, 2026, passed by a Single Judge of the Delhi High Court in a contempt petition

The original contempt petition alleged that the husband willfully violated maintenance orders. The Appellants were impleaded by the Single Judge on the allegation that they aided and abetted the contempt by operating a family business (Adore Insurance Marketing LLP) designed to artificially suppress the husband's income

The Single Judge issued notice to the Appellants and directed their personal appearance in court

The Appellants filed the present appeal under Section 19(1) of the Contempt of Courts Act, 1971, contending they had no role in the alleged violation

1. Whether an appeal under Section 19(1) of the Contempt of Courts Act, 1971, is maintainable against an order that merely impleads parties and directs their personal appearance without imposing punishment

Section 19(1) of the Contempt of Courts Act, 1971, which provides a right of appeal only from an "order or decision" of the High Court "in the exercise of its jurisdiction to punish for contempt"

Midnapore Peoples’ Coop. Bank Ltd. v. Chunilal Nanda (2006) 5 SCC 399, which established that an appeal is maintainable only against an order imposing punishment, and notably, an order initiating proceedings or impleading parties is not appealable under this section

Tribhuwan Singh & Ors. v. Shri Chetan Prakash Jain & Anr. (CONT.APP.(C) 6/2026) to reinforce that orders refusing to punish or incidental orders do not qualify for a Section 19 appeal

The Court examined the nature of the impugned order dated March 12, 2026, and observed that the Single Judge had only issued notice, impleaded the Appellants, and directed their presence to investigate the "aiding and abetting" allegations

Applying the Midnapore doctrine, the Division Bench noted that the Single Judge had not yet exercised jurisdiction to "punish" the Appellants

Since Section 19 is strictly reserved for orders that actually inflict punishment or finality regarding the contempt jurisdiction, a procedural order impleading family members as "proposed respondents" is interlocutory/incidental in nature

The court concluded that until a decision regarding punishment is reached, the statutory right of appeal under Section 19 is not triggered

The appeal and pending applications were rejected, though the Court clarified it had not touched upon the merits of the case and all contentions remained open for the Appellants to raise before the Single Judge