Contempt court cannot decide merits or issue fresh directions beyond the scope of the original order.

The respondent, Rajendra Prasad, filed a declaratory suit under Section 229-B of the U.P.Z.A. & L.R. Act, which was initially dismissed but later remanded by appellate authorities. The appellant challenged this remand in Writ B No. 30424 of 2012.

On 16.12.2024, the Writ Court disposed of the petition, directing the Trial Court to decide whether to permit the respondent to cure suit defects or file a fresh suit under Order VII Rule 13 CPC.

The respondent moved an application before the Sub Divisional Magistrate (SDM) simply asking for "compliance" with the writ order without specifying the relief sought (curing defects or fresh suit).

The SDM rejected the application on 20.01.2026 on merits.

The respondent filed a contempt application. On 28.03.2026, the learned Single Judge (Contempt Court) disposed of the application by granting the respondent fresh liberty to move the Trial Court.

The appellant filed this intra-court appeal challenging the Contempt Court's jurisdiction to grant such relief.

1. Whether an intra-court appeal is maintainable against an order passed by a Single Judge in contempt jurisdiction if that order decides merits or issues directions beyond the original decree.

2. Whether the Contempt Court exceeded its jurisdiction by granting fresh liberty to the respondent after the SDM had already passed a dynamic order on the application.

The Court primarily applied Chapter VIII Rule 5 of the High Court Rules, 1952 regarding intra-court appeals.

If a Contempt Court decides an issue on merits or issues directions relating to the dispute, an intra-court appeal is maintainable pursuant to the Supreme Court precedent in Midnapore Peoples Cooperative v. Chunni Lal Nanda.

A court exercising contempt jurisdiction cannot go behind the original order, supplement directions, or touch upon the merits of the underlying controversy as per Subhash Chandra v. Srikant Goswami and Vinod Kumar Sharma v. Shiv Mohan Dwivedi.

The Court found that the SDM had technically complied with the Writ Court's direction by passing an order on 20.01.2026, even if that order resulted in the rejection of the respondent's application.

The Contempt Court’s role is limited to verifying whether "willful disobedience" occurred; it does not possess the authority to review the correctness of the SDM's order or grant fresh procedural liberties.

By granting the respondent another opportunity to file a fresh application, the Single Judge (Contempt Court) "overstepped" its jurisdiction and entered the domain of writ jurisdiction under Article 226/227.

Since the impugned order had the "trappings of a final order" affecting the substantive rights of the parties, the intra-court appeal was held maintainable despite arising from contempt proceedings.

The High Court allowed the appeal and set aside the Single Judge’s order dated 28.03.2026, while clarifying that the respondents remain free to challenge the SDM’s rejection order through appropriate legal channels under the U.P.Z.A. & L.R. Act.