Karnataka HC Drops Farmers’ Contempt Case After Land Officer’s Delayed Endorsement, Leaves Them Free To Challenge It

In brief

The question

Whether the Assistant Commissioner’s subsequent consideration of the complainants’ representations and issuance of a fresh endorsement meant that the contempt petition no longer survived for consideration.

The court held

The Court took the compliance affidavit on record and dropped the contempt proceedings; it also discharged the notice issued to the respondent.

It also directed

The complainants were granted liberty to challenge the Assistant Commissioner’s endorsement, if they wished.

01Facts

The complainants alleged disobedience of the order dated 20 November 2023 in W.P. No. 203072/2023, which directed the Deputy Commissioner and the Special Land Acquisition Officer/Assistant Commissioner to consider their representation, or a fresh representation, within eight weeks of receiving the Court’s order.

p. 3

The complainants submitted fresh representations in February 2024; the Assistant Commissioner later issued an endorsement on 25 June 2025, but it did not refer to the dates of those representations.

pp. 3-p.5

After receiving the contempt notice, the Assistant Commissioner issued a fresh endorsement on 8/9 October 2026, stated that it had been communicated to the complainants, and tendered an unconditional apology for the delay.

pp. 5-p.6

The complainants had initiated contempt proceedings under Sections 11 and 12 of the Contempt of Courts Act, 1971 and Article 215 of the Constitution.

p. 2

02Issues

i.Whether the Assistant Commissioner’s subsequent consideration of the complainants’ representations and issuance of a fresh endorsement meant that the contempt petition no longer survived for consideration.

pp. 5-p.7

ii.Whether the delay in complying with the Single Judge’s order warranted continuation of contempt proceedings despite the compliance and unconditional apology.

pp. 5-p.7

03Law Applied

The petition invoked Sections 11 and 12 of the Contempt of Courts Act, 1971, and Article 215 of the Constitution of India, concerning the High Court’s contempt jurisdiction.

p. 2

The underlying order required the authorities to consider the complainants’ representation, or a fresh representation, within eight weeks of receiving the Court’s order.

p. 3

The Court did not cite any precedent or separately articulate a test for civil contempt; it disposed of the petition on the basis of the compliance affidavit and the stated compliance with the underlying direction.

pp. 5-p.7

Provisions in the judgment · 2 · Linked ones open on LawLens

Contempt of Courts Act, 1971 Section 11 Section 12

04Reasoning

The Assistant Commissioner’s affidavit stated that an endorsement had been issued in June 2025, that its omission of the representation dates was inadvertent, and that a fresh endorsement was issued after receipt of the contempt notice.

pp. 4-p.6

The Court accepted the affidavit as showing compliance with the Single Judge’s order and noted the unconditional apology for the delay.

p. 7

On that basis, it concluded that the contempt petition no longer survived for consideration.

p. 7