Karnataka High Court
Civil Procedure and EvidenceAdministrative and Public Law

Retrospective validation of the levy rendered the contempt petitions infructuous.

SRI. M. RAMU vs SRI. TUSHAR GIRINATH

Karnataka High CourtJUDGMENT: September 28, 20261 MIN READSOURCE JUDGMENT
Retrospective validation of the levy rendered the contempt petitions infructuous.. SRI. M. RAMU vs SRI. TUSHAR GIRINATH. Karnataka High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

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

Source reference: no citation

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.

Source reference: p. 17

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.

Source reference: p. 18
02

Issues

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

Source reference: p. 18

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

Source reference: p. 18
03

Law Applied

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

Source reference: pp. 2–3, 4–5

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.

Source reference: p. 18

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

Source reference: no citation
04

Reasoning

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

Source reference: p. 18

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.

Source reference: p. 18

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

Source reference: p. 18
05

Holding

The Court held that no case of contempt survived for consideration.

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

Source reference: p. 18
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

SRI. M. RAMUvsSRI. TUSHAR GIRINATH

Karnataka High Court · September 28, 2026

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