Contemnor cannot retain benefits of delay; Court may award compensatory interest and costs for wilful disobedience.

The petitioner’s late father held two Fixed Deposits (FDRs) under the “Kuber Yojana Deposit Scheme” at UCO Bank

Following his father's death in 2004, the petitioner obtained a Succession Certificate on 18.05.2023 from the Saket Courts, specifically authorizing the collection of these FDR balances

Despite submitting the required documents, the bank failed to release the funds, leading the petitioner to file W.P.(C) 16096/2023. Although the Court directed the bank to take steps per the Succession Certificate on 24.02.2025, the bank remained recalcitrant

The petitioner then filed this contempt petition, prompting the bank to release the principal amount on 10.03.2025, but with only 6% simple interest for the post-maturity period

1. Whether the delay in releasing the FDR amounts following the grant of a Succession Certificate constitutes wilful disobedience of judicial orders

2. Whether the Court, in its contempt jurisdiction, can grant additional interest and costs to compensate a petitioner for the loss of the "fruits" of a judgment due to a respondent's delay

The Court applied the principle that a contemnor cannot be permitted to enjoy the fruits of wilful disobedience, as established in DDA v. Skipper Construction Co. (P) Ltd.

It relied on Balwantbhai Somabhai Bhandari v. Hiralal Somabhai, which held that the majesty of law requires nullifying any advantage secured through contumacious conduct

The Court applied the rationale from Anuradha Sharma v. Tis Hazari Courts, asserting that a court in contempt jurisdiction has the power to reverse the "aggravation" caused by the non-implementation of an order by granting interest, as money depreciates over time

The Court found that while the bank complied with its internal policy regarding post-maturity interest rates, there was no valid justification for the delay in releasing the funds between the issuance of the Succession Certificate (18.05.2023) and the actual payout (10.03.2025)

The Court determined that this delay resulted in an infraction of the orders passed in the Succession Case and subsequent writ proceedings

Reasoning that no litigant should suffer due to the bank's recalcitrance or the court's process, the Court held that the only way to remedy the "wrong" and maintain the majesty of law was to ensure the petitioner was compensated for the period he was deprived of his legitimate dues

The bank must pay litigation expenses of Rs. 1,00,000/- to the petitioner due to the multiple proceedings required to realize the amount, and all payments must be disbursed within 15 days, upon which the Court refrained from further action against the bank officials and disposed of the petition