Retrospective validation of the levy rendered the contempt petitions infructuous.

The complainants filed contempt petitions alleging non-compliance with directions issued in several writ petitions concerning a levy.

The Court recorded that the petitions arose from directions in W.P. No. 4601/2020 and a common judgment in Mr. Sunderam Chetty v. State of Karnataka and others and connected writ petitions.

It was brought to the Court’s attention that, after the judgment, the State enacted the Municipal Corporations and Certain Other Laws (Amendment) Act, 2021 (Karnataka Act No. 1 of 2022), validating the levy retrospectively.

1. Whether the contempt petitions remained live for consideration following the enactment of the retrospective validating legislation.

2. Whether the petitions should be dismissed as infructuous in light of that subsequent development.

The petitions were brought under Sections 11 and 12 of the Contempt of Courts Act, 1971.

The Court’s operative reasoning was that the subsequent enactment—the Municipal Corporations and Certain Other Laws (Amendment) Act, 2021 (Karnataka Act No. 1 of 2022)—validated the levy retrospectively, rendering the contempt petitions infructuous or ineffective.

The Court cited no precedent and did not set out or apply a separate test for civil contempt.

The Court noted that the State had enacted retrospective validating legislation after the judgment whose directions were said to have been disobeyed.

In view of that subsequent development, it concluded that no case of contempt survived for consideration and that the petitions had become infructuous or ineffective.

The Court did not separately determine whether the alleged disobedience had been deliberate or adjudicate the underlying validity of the levy.

The Court dismissed all the connected contempt petitions as having been rendered infructuous.