### Government Departments Must Coordinate to Ensure Execution of Recovery Certificates Issued Against the State

The Petitioners sought the execution of an Award dated 26.03.2024, pursuant to which recovery certificates were issued on 01.07.2025.

Despite previous court orders dated 28.04.2026 directing progress, the certificates remained unexecuted.

The Government of NCT of Delhi (GNCTD) argued that the certificates were issued against the Department of Rural Development instead of the Department of Revenue, despite an earlier judicial amendment to the Award's cause title to rectify the respondent's name.

The GNCTD contended that its departments function independently, leading to a lack of coordination in executing internal department-to-department recoveries.

Whether the GNCTD can delay the execution of a recovery certificate based on internal departmental jurisdictional disputes.

What measures should be taken to streamline the execution of awards against government departments to avoid procedural gridlock.

The Court emphasized the principle of state accountability and the necessity of administrative coordination to ensure the efficacy of judicial awards.

In W.P.(C) 5436/2020, a coordinate bench held that the salaries of concerned officials could be withheld until recovery certificates are executed to ensure compliance.

The overarching principle applied is that the State cannot use its own internal administrative fragmentation as a shield against the execution of a valid legal award.

The Court expressed concern over the "spectacle" of the GNCTD being unable to execute an award against itself.

It rejected the technical plea that the certificates were issued against the "wrong department," noting that the cause title had already been amended by a previous judicial order.

The Court observed a systemic failure within the GNCTD where no mechanism exists to prevent or resolve coercive actions between its own departments.

While the Petitioners requested the extreme measure of withholding official salaries as per prior precedents, the Court opted for a hierarchical administrative solution first.

By involving the Chief Secretary, the Court sought to compel the GNCTD to "set its own house in order" rather than allowing internal bureaucracy to frustrate the rights of the decree-holders.

It requested the Chief Secretary, GNCTD, to intervene and liaise between the Department of Revenue and the Department of Rural Development to streamline the execution process for these and similar cases.

The Court held that if compliance is not achieved within the stipulated timeframe, the Secretaries of the Department of Revenue and the Department of Rural Development are required to appear virtually at the next hearing on 14.10.2026.