Karnataka High Court
Civil Procedure and EvidenceAdministrative and Public Law

Contempt proceedings do not survive once the court’s directions have been complied with.

SHARANAPPA B PATIL @ S B PATIL vs THE SUPERINTENDING ARCHAEOLOGIST

Karnataka High CourtJUDGMENT: September 30, 20262 MIN READSOURCE JUDGMENT
Contempt proceedings do not survive once the court’s directions have been complied with.. SHARANAPPA B PATIL @ S B PATIL vs THE SUPERINTENDING ARCHAEOLOGIST. Karnataka High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

In W.P. No. 202651/2025, the Single Judge directed the respondents to consider the complainant’s representation dated 2 July 2025 in accordance with law, if not already considered, within four weeks of receiving the certified copy of the order.

Source reference: p. 3

A previous contempt petition was disposed of on 16 June 2026 with directions to facilitate a joint survey and for the respondents to decide the complainant’s request within three weeks.

Source reference: pp. 3–5

The respondents’ affidavit stated that a joint survey was conducted on 18 September 2026 and its report was received on 22 September; an endorsement dated 28 September 2026 informed the complainant that the available records did not clarify whether the land formed part of land under the Archaeological Survey of India’s ownership, control, or custody.

Source reference: pp. 6–7

The complainant alleged that the court’s directions had not been obeyed.

Source reference: p. 5
02

Issues

1. Whether the respondents’ delay and their handling of the representation amounted to disobedience of the court’s orders warranting contempt proceedings

Source reference: pp. 3–5, 7–8

2. Whether the contempt petition survived for consideration after the respondents filed an affidavit stating that they had acted on the representation and tendering an unconditional apology

Source reference: pp. 7–8
03

Law Applied

The petition was brought under Sections 11 and 12 of the Contempt of Courts Act, 1971, read with Article 215 of the Constitution of India.

Source reference: p. 2

The court’s stated basis for disposing of the matter was that the directions in the writ petition and the earlier contempt proceedings had been complied with; it did not set out a separate test for civil contempt or rely on any precedent in this order.

Source reference: pp. 7–8
04

Reasoning

The court considered the compliance affidavit, which described the joint survey, the resulting endorsement, the reasons given for delay, and the deponent’s unconditional apology.

Source reference: pp. 6–7

On that material, it concluded that the respondents had complied with the earlier directions. It therefore treated the contempt petition as no longer requiring consideration, without determining the merits of the respondents’ assessment of the land’s status.

Source reference: pp. 7–8
05

Holding

The court held that the relevant directions had been complied with and that the contempt petition did not survive for consideration.

It took the compliance affidavit on record, dropped the petition, and discharged the notice.

Source reference: p. 8

It reserved liberty to the complainant to challenge the respondents’ action in accordance with law.

Source reference: p. 8
06

Acts & Sections Cited

2 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Contempt of Courts Act, 19712

Karnataka High Court

Original Court PDF

SHARANAPPA B PATIL @ S B PATILvsTHE SUPERINTENDING ARCHAEOLOGIST

Karnataka High Court · September 30, 2026

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