Contempt cannot lie where the authority complied with directions to consider the representation; merits remain open.

The petitioner had been allotted a 50-square-metre warehousing plot at IFC Holambi Kalan, Narela, Delhi, and received the allotment letter on 18 October 2019.

After the DDA issued a show-cause notice concerning non-submission of documents, the petitioner claimed to have submitted the requisite documents on 26 April 2022.

In W.P.(C) 2505/2025, the High Court directed the DDA to treat the writ petition as a representation and decide it in accordance with law within four weeks, while clarifying that no view had been expressed on the merits and reserving the parties’ rights.

Alleging wilful disobedience and delay in execution of the lease deed, the petitioner initiated contempt proceedings.

The DDA filed a compliance affidavit, conducted the necessary examination and hearing, stated that it intended to execute the lease deed, issued a physical possession slip, and subsequently required further documents and demanded Rs. 3,59,347 as outstanding dues before execution of the lease deed.

The petitioner disputed the monetary demand.

Whether the DDA wilfully disobeyed the High Court’s order directing it to consider the petitioner’s writ petition as a representation and decide it in accordance with law.

Whether the petitioner’s dispute regarding the DDA’s demand of Rs. 3,59,347 could be adjudicated in the contempt proceedings.

Contempt jurisdiction is concerned with determining whether a binding judicial direction has been complied with and whether any non-compliance is wilful; it does not ordinarily adjudicate claims that were not decided in the original proceedings.

Where an order merely directs an authority to consider and decide a representation in accordance with law, compliance is assessed by examining whether the authority considered the matter and took a decision, not by examining whether the decision is substantively favourable to the claimant.

Issues expressly left open by the original order, including disputed monetary liabilities, must be pursued through independent remedies and cannot be conclusively determined in contempt proceedings.

The original writ order did not direct the DDA unconditionally to grant the lease or decide the petitioner’s entitlement on merits; it required the DDA to treat the writ petition as a representation and decide it in accordance with law, expressly recording that no merits had been adjudicated.

The DDA demonstrated procedural compliance by examining the matter, providing the petitioner an opportunity of hearing, communicating its intention to execute the lease deed, issuing a physical possession slip, and seeking documents and payment of alleged outstanding dues.

Accordingly, the Court found no wilful disobedience.

Since the original writ proceedings had not determined the amount payable by the petitioner, the Court declined to examine the correctness of the Rs. 3,59,347 demand in contempt jurisdiction.

No further order was required in the contempt proceedings.

The petitioner was granted liberty to pursue remedies in accordance with law to challenge the DDA’s demand of Rs. 3,59,347.

The contempt petition and pending application were disposed of, and the next date of hearing was cancelled.