Original authority retains jurisdiction to implement judicial directions notwithstanding subsequent transfer of territorial limits.

The petitioners filed a contempt petition under Section 12 of the Contempt of Courts Act, 1971, alleging the non-implementation of a judgment dated 16.09.2025 passed in W.P.(C) No. 24710 of 2025.

In the original writ jurisdiction, the Court had directed the Sub-Registrar of Titilagarh (the contemnor) to receive and process a sale deed submitted by the petitioners in accordance with the Indian Registration Act, 1908, and the Orissa Registration Rules, 1988.

The contemnor filed a show-cause affidavit asserting that the land in question (Mouza-Dhanput) had since been transferred from the jurisdiction of the Sub-Registrar, Titilagarh, to a newly established Sub-Registrar office in Saintala, thereby rendering him unable to register the deed.

1. Whether the transfer of territorial jurisdiction to a new registration office subsequent to a Court directive exonerates the original authority from implementing said directive.

The Court primarily applied Section 12 of the Contempt of Courts Act, 1971, regarding the willful disobedience of judicial orders.

It relied on the Indian Registration Act, 1908, and the Orissa Registration Rules, 1988, as the regulatory framework for deed registration.

The Court applied the legal principle established by the Full Bench of the Orissa High Court in In the matter of District Judge, Puri, 36 (1970) CLT 1026 (F.B.), which holds that an original court or authority retains jurisdiction over a matter even if the area containing the disputed property is transferred out of its local jurisdiction after the institution of the proceeding.

The Court rejected the contemnor’s argument that the creation of the Saintala Sub-Registrar office created a legal impediment to registration.

Applying the precedent from the Full Bench in District Judge, Puri, the Court reasoned that because the Sub-Registrar of Titilagarh possessed original jurisdiction at the time the writ petition was decided (16.09.2025), he "retains its power" to execute the registration despite the subsequent administrative realignment of Mouza-Dhanput.

The Court observed that since jurisdiction existed on the date the judgment was passed, there was no valid legal barrier preventing the contemnor from fulfilling the Court's mandate.

Consequently, the defense raised in the show-cause affidavit was deemed "not acceptable under law".

The Court directed the contemnor to implement the judgment dated 16.09.2025 immediately.

On the basis of these clarifications and the mandate for immediate compliance, the contempt petition was dropped and disposed of.