Madras High Court Closes Contempt Petition Filed by Senior Citizens Against Officers of Tamil Nadu Electricity Board for Disobedience of Order in W.A. No. 424/2021; Contempt Closed Pursuant to Order in Review Application

High Court: Madras High Court Bench: Principal In Favour of Accused
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Case Note & Summary

The contempt petition arose from an earlier writ appeal (W.A. No. 424 of 2021) concerning service matters of former employees of the Tamil Nadu Electricity Board. Forty-five petitioners, all retired senior citizens, alleged that the respondents—officials of the Ennore Thermal Power Station—had deliberately disobeyed a direction issued by the High Court on 10 November 2023. The petitioners sought punishment of the respondents under the Contempt of Courts Act, 1971. The specific direction violated was not detailed in the contempt proceedings, but the petitioners claimed willful non-compliance. During the pendency of the contempt case, a review application (Review Application No. 20 of 2025) was filed, presumably in relation to the original writ appeal order. On 3 February 2025, a Division Bench of the Madras High Court, comprising Justices S.M. Subramaniam and K. Rajasekar, took up the contempt petition for disposal. The court noted that orders had been passed in the review application. In view of that development, the contempt petition was closed with no order as to costs. The decision effectively rendered the contempt proceedings infructuous, as the underlying issue had been addressed in the review forum. No finding of contempt was recorded, and the court did not delve into the merits of the alleged disobedience. The closure without costs suggests that the court found the petition no longer necessary or that the review order remedied the grievance. The judgment is a brief speaking order, with no detailed discussion of facts or law. Thus, the matter stands disposed of as closed.

Headnote

A) Contempt of Court - Disobedience of Court Order - Contempt of Courts Act, 1971, Sections 10, 11, 12 - The contempt petition alleged deliberate disobedience of the High Court order dated 10.11.2023 in W.A. No. 424 of 2021. During the pendency, a review application was filed and orders were passed. In view of the orders in Review Application No. 20 of 2025, the High Court closed the contempt petition without costs. Held that where a review order intervenes, the contempt proceedings become infructuous and are closed.

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Issue of Consideration

Whether the respondents committed contempt of court by willfully disobeying the order dated 10.11.2023 in W.A. No. 424 of 2021

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Final Decision

The contempt petition is closed. No costs.

Law Points

  • contempt petition closed based on review application outcome
  • contempt of court when original order superseded by review
  • no costs when contempt not proved
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Case Details

2025 LawText (MAD) (02) 26

CONT.P.No.2690 of 2024

2025-02-03

S.M. Subramaniam, K. Rajasekar

TR.K. Shamugakani, Anand Gopalan

S. Ravi and 44 others

V. Gunaselvam, Chief Engineer, Ennore Thermal Power Station & Anr.

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Nature of Litigation

Contempt petition alleging willful disobedience of a court order

Remedy Sought

Punishment of the respondents under the Contempt of Courts Act, 1971 for deliberately disobeying the direction issued by the High Court on 10.11.2023 in W.A.No.424 of 2021

Filing Reason

The respondents, officers of Ennore Thermal Power Station, allegedly failed to comply with the High Court order dated 10.11.2023 in the writ appeal.

Previous Decisions

The High Court passed an order in W.A. No. 424 of 2021 on 10.11.2023; subsequently, Review Application No. 20 of 2025 was filed and orders were passed, leading to the closure of the contempt petition.

Issues

Whether the respondents committed contempt of court by willfully disobeying the order dated 10.11.2023 in W.A. No. 424 of 2021

Submissions/Arguments

Petitioners submitted that the respondents deliberately disobeyed the court's direction; respondents presumably denied contempt or sought closure in view of the review application.

Ratio Decidendi

Where a review application has been filed and orders passed in the main matter, the contempt petition arising from the original order may be closed without costs, as the underlying issue stands resolved or superseded.

Judgment Excerpts

In view of the orders passed in Review Application No.20 of 2025, the contempt petition is hereby closed. No costs. Contempt Petition has been filed under Sections 10, 11 and 12 of the Contempt of Courts Act, 1971, pleased to punish the respondents for the contempt committed by them in deliberately disobeying the direction issued by this Court dated 10.11.2023 in W.A.No.424 of 2021.

Procedural History

The High Court passed an order in W.A. No. 424 of 2021 on 10.11.2023. The petitioners filed Contempt Petition No. 2690 of 2024 alleging deliberate disobedience of that order. During pendency, Review Application No. 20 of 2025 was filed and orders were passed. On 03.02.2025, the High Court closed the contempt petition in view of the review order, with no costs.

Acts & Sections

  • Contempt of Courts Act, 1971: 10, 11, 12
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