Validity of a Decision Under Contempt Jurisdiction Cannot Be Examined Once the Underlying Order Is Complied With

The Petitioner, a recognized B.Ed. college, applied to the National Council for Teacher Education (NCTE) on 13.09.2007 and 23.10.2013 for permission to shift premises.

Due to administrative inaction, the Petitioner filed W.P.(C) 1207/2026, wherein the Court, on 29.01.2026, directed the NCTE to decide the application within six weeks.

Following non-compliance, the Petitioner filed a first contempt petition (CONT. CAS(C) 469/2026), resulting in a second order dated 20.03.2026, which warned that failure to decide within four weeks would be construed as a "wilful and egregious breach".

The present contempt petition was filed alleging continued disobedience of those directions.

1. Whether the Respondents committed wilful disobedience of the Court’s orders dated 29.01.2026 and 20.03.2026 under the Contempt of Courts Act, 1971.

2. Whether the validity and procedural propriety of an administrative decision taken during the pendency of contempt proceedings can be adjudicated within the scope of said proceedings.

The court primarily applied Sections 11 and 12 of the Contempt of Courts Act, 1971, which govern the punishment for wilful disobedience of court orders, read with Article 215 of the Constitution of India regarding the High Court’s power to punish for contempt.

The merits or "validity" of an order passed by an authority in purported compliance cannot be examined within the narrow jurisdiction of contempt proceedings.

The Court reviewed the Respondents' submission that a decision on the Petitioner's application had finally been taken on 02.06.2026, resulting in a rejection.

While the Petitioner argued that the decision was procedurally flawed because it was made without a physical inspection of the premises, the Court observed that its primary mandate in this contempt petition was to ensure the direction to "decide" was implemented.

Since a categorical decision had been rendered and communicated, the "wilful disobedience" element was no longer sustainable.

The Court highlighed that any grievance regarding the procedural deficiencies or the merits of the rejection must be challenged through separate appropriate legal proceedings rather than through a contempt plea.

The Petition was disposed of as infructuous, with liberty granted to the Petitioner to assail the rejection order dated 02.06.2026 in appropriate proceedings.