Section 19 appeals lie only against orders imposing punishment for contempt.

The appellant challenged, under Section 19(1)(a) of the Contempt of Courts Act, 1971, the order dated 27 July 2026 passed by the learned Single Judge in Cont. Cas. (C) 1295/2026, concerning alleged non-compliance with a Family Court order directing payment of maintenance to the respondent.

The Single Judge recorded that the appellant had been paying ₹10,000 per month against the ordered amount of ₹20,000 per month, noted alleged arrears of ₹5,60,000, granted the appellant liberty to file a response, and directed compliance with the relevant orders and payment of arrears.

The appellant also sought clubbing of the multiple proceedings allegedly pending between the parties, who were stated to be husband and wife and practising lawyers.

Whether an order in contempt proceedings directing compliance with a maintenance order and payment of arrears, without imposing punishment for contempt, is appealable under Section 19(1)(a) of the Contempt of Courts Act, 1971.

Whether the appellant’s request for clubbing the various proceedings between the parties could be granted in the present appeal.

Section 19 of the Contempt of Courts Act, 1971 permits an appeal only against an order or decision of the High Court passed in the exercise of jurisdiction to punish for contempt, namely, an order imposing punishment.

Relying on Midnapore Peoples’ Coop. Bank Ltd. v. Chunilal Nanda, (2006) 5 SCC 399, the Court held that orders initiating, declining to initiate, dropping, or otherwise dealing with contempt proceedings without imposing punishment are not appealable under Section 19; directions concerning the merits of the underlying dispute are likewise not appealable unless incidental or inextricably connected with an order punishing for contempt.

The Court also followed its decisions in R.K. Sharma v. Sh. Amarjeet Singh, CONT.APP.(C) 23/2025, and Tribhuwan Singh v. Shri Chetan Prakash Jain, CONT.APP.(C) 6/2026.

The impugned order merely directed the appellant to comply with the existing maintenance orders and pay the alleged arrears; it did not adjudicate the appellant guilty of contempt or impose any punishment.

Applying the rule in Midnapore Peoples’ Coop. Bank, the Court concluded that such a direction was not an appealable order under Section 19 because it was neither an order punishing for contempt nor incidental to such punishment.

As to clubbing, the Court held that the request should first be made through an appropriate application before the learned Single Judge rather than being determined in the statutory contempt appeal.

The appellant was granted liberty to seek clubbing of the proceedings by filing an appropriate application before the learned Single Judge in accordance with law.

The appeal was accordingly disposed of, and pending applications were also disposed of.