Contempt courts cannot issue fresh or supplemental directions beyond the original order.

The dispute concerned the management and performance of daily poojas at the Arulmigu Kaliamman Temple, a private temple at Parukkal Village, Ariyalur District.

Owing to disputes between rival local groups, the police had locked the temple premises to maintain public order.

Desikan filed W.P.No.6670 of 2025 seeking the temple’s unlocking and return of the keys to enable him to perform daily poojas.

On 26.02.2025, the learned Single Judge permitted V. Veeramani, described as a neutral person, to perform the daily pooja and directed the disputing parties to approach the competent Civil Court to establish their civil rights.

The writ appeal against that order was dismissed, and the Supreme Court dismissed the appellant’s SLP, leaving the parties to pursue their remedies before the Civil Court.

Thereafter, Veeramani filed Contempt Petition No.2080 of 2025 alleging non-compliance.

On 30.07.2025, the learned Single Judge appointed additional persons to perform poojas, directed the police to hand over safety-locker keys to the RDO, ordered an administrative enquiry between the rival groups, and directed that the temple be opened for public worship.

In Sub Application No.932 of 2025, the Court subsequently issued further directions concerning the temple locks and distribution of keys between the rival groups.

The present Letters Patent Appeals challenged those contempt-court orders.

Whether a court exercising contempt jurisdiction can issue fresh, modified, or supplemental directions beyond the express terms of the original order alleged to have been violated.

Whether the learned Single Judge exceeded the limits of contempt jurisdiction by creating a new administrative mechanism for the temple and issuing directions concerning pooja rights, keys, lockers, police action, and revenue enquiries.

The Court applied the settled limits of contempt jurisdiction under the Contempt of Courts Act, 1971 and the constitutional contempt powers of superior courts.

Relying principally on Sudhir Vasudeva v. M. George Ravishekeran, (2014) 3 SCC 373, the Court held that a contempt court must remain within the “four corners” of the order allegedly disobeyed; it may consider only directions that are explicit or plainly self-evident, but cannot reopen decided issues, consider equitable claims, or issue supplemental directions altering or expanding the original order.

Contempt jurisdiction cannot be used as a substitute for review or appeal, nor can it be exercised to adjudicate disputed civil rights or create a new remedial or administrative framework.

The Court also applied the principle that disputed rights concerning the temple had to be determined by the competent Civil Court, as directed in the original writ order and affirmed in appeal.

The original order dated 26.02.2025 merely permitted Veeramani to conduct daily pooja as an interim neutral arrangement and relegated the rival parties to the Civil Court for determination of their civil and administrative rights.

The contempt court’s function was therefore limited to determining whether there had been wilful disobedience of that specific order.

Instead, the impugned order appointed additional poojaris, required the RDO to conduct an enquiry and pass administrative orders, regulated custody of temple and locker keys, and directed the temple’s opening for public worship.

These directions did not enforce an explicit term of the original order; they supplemented and materially altered the interim arrangement and effectively established a new temple-administration mechanism.

Since such adjudication and modification could only be pursued through an appropriate civil, appellate, or review proceeding, the learned Single Judge acted beyond the permissible scope of contempt jurisdiction.

Accordingly, the orders dated 30.07.2025 in Contempt Petition No.2080 of 2025 and 13.08.2025 in Sub Application No.932 of 2025 were set aside, and all three appeals were allowed.

The parties were left at liberty to establish their respective rights before the competent Civil Court, which was directed to decide the pending suit on its own merits, uninfluenced by the observations in the judgment.

No order was made as to costs, and the connected interim applications were closed.