Consideration and rejection of a representation pursuant to court directions does not constitute wilful disobedience.

The petitioner, Syed Moula, filed this contempt petition under Sections 11 and 12 of the Contempt of Courts Act, 1971, alleging that the respondents willfully disobeyed the Madras High Court's order dated 04.09.2025 in W.P.No.33727 of 2025

In the underlying writ petition, the Court had dislodged a communication involving coercive action (subject to the State's rights under the 1905 Act) and directed the State to consider the petitioner’s request for the issuance of a patta

The petitioner contended that the failure to grant the patta or properly execute the order constituted contempt

Whether the respondents’ act of rejecting the petitioner’s application for patta, after having been directed by the Court to "consider" said application, amounts to "wilful disobedience" under the Contempt of Courts Act

The Court exercised its jurisdiction under Sections 11 and 12 of the Contempt of Courts Act, 1971, read with Article 215 of the Constitution of India

The primary legal principle applied is that a judicial direction to "consider" a representation is satisfied when the administrative authority applies its mind and passes an order on the merits of the request.

Furthermore, "wilful disobedience" requires a deliberate intent to flout a court order, which is absent if the directed procedural step (consideration) has been performed, even if the result is unfavorable to the petitioner

The Court analyzed the scope of its previous direction, which mandated the State to "consider" the petitioner's request for a patta

The Special Government Pleader submitted that the authorities had processed the application and ultimately rejected it

The Court reasoned that since the authorities had taken a formal decision on the application, the specific direction issued in the writ petition had been complied with

The Court emphasized that the merits of the rejection itself cannot be adjudicated in a contempt proceeding; rather, if the petitioner seeks to challenge the grounds of the rejection, he must initiate separate legal proceedings "in the manner known to law"

Consequently, the Court found no evidence of a deliberate or "wilful" attempt to defy the judicial mandate

Finding no "wilful disobedience" of the order dated 04.09.2025, the Court dismissed the Contempt Petition