Authorities Cannot Interpret Court Orders On Their Own – Proper Course Was To Seek Clarification: Madras High Court Upholds One Month Civil Imprisonment For Disbursing ₹20 Crores In Violation Of Interim Order

"Once An Order Of This Court Has Been Violated, The Contempt Is Complete – Subsequent Recovery Will Not Erase The Violation", In a stern reaffirmation of judicial authority, the High Court of Judicature at Madras on 23 February 2026 dismissed Contempt Appeal No.23 of 2023 and upheld the conviction and sentence imposed on a Special District Revenue Officer for wilful disobedience of an interim order directing deposit of land acquisition compensation.

The Division Bench comprising Justice P. Velmurugan and Justice M. Jothiraman held that disbursement of nearly ₹20 Crores to private individuals, despite a subsisting interim direction to deposit the compensation in a fixed deposit in the name of the Registrar General of the Court, amounted to clear and deliberate contempt. The sentence of one month civil imprisonment imposed by the learned Single Judge was affirmed, with a direction to undergo the remaining period.

The appeal arose under Section 19 of the Contempt of Courts Act, 1971 challenging the order dated 04.08.2023 passed in Cont.P.No.642 of 2020.

The controversy traces back to land acquisition proceedings initiated under the National Highways Act, 1956 for the Bangalore–Chennai Expressway project in Sriperumbudur Taluk, Kanchipuram District. The writ petitioner had contended that certain lands earmarked as Open Space Reservation lands in approved layouts had already vested with the local body and therefore compensation could not be disbursed to private individuals claiming ownership.

On 10.02.2020, in W.M.P.No.3683 of 2020 in W.P.No.3177 of 2020, the High Court passed a clear interim order directing that after determining compensation payable for the acquired lands, the amount shall be invested in an interest-fetching fixed deposit in a nationalised bank in the name of the Registrar General of the Court, until further orders. The purpose was explicit — to safeguard the compensation until entitlement was adjudicated.

Despite the clarity of the direction and its official communication, including forwarding by the District Collector and repeated representations from the writ petitioner, compensation was disbursed to private parties. Contempt proceedings followed.

Before the Division Bench, the appellant contended that the disbursement was based on revenue records, statutory notifications and encumbrance details; that the lands were reflected as private lands; and that the interim order was understood to apply only to OSR lands. It was argued that there was no wilful disobedience and that the essential ingredient of “wilfulness” was absent. It was also urged that the amount had subsequently been recovered and that the appellant had already undergone 19 days of civil imprisonment.

Rejecting these submissions, the Bench emphasized that once a court order is in force, authorities are bound to comply strictly. The Court observed that if there was any doubt regarding interpretation, “the proper course was to approach this Court by filing an appropriate application seeking clarification, modification or vacating of the interim order.” Authorities cannot assume the role of interpreters of judicial directions.

The Bench categorically held that the directions in the interim order “are clear and leave no scope for doubt.” The compensation was required to be deposited and not disbursed. The magnitude of the amount involved — nearly ₹20 Crores — demanded heightened diligence, not unilateral interpretation.

Addressing the argument that the lands were recorded as private lands in revenue records, the Court drew a clear line between contempt jurisdiction and merits of the underlying dispute. It held that in contempt proceedings, “the only question to be considered is whether the order of this Court has been violated. The correctness of the order or the merits of the case cannot be examined in contempt jurisdiction.”

On the issue of knowledge, the Court recorded that the interim order dated 10.02.2020 had been officially communicated, forwarded by the District Collector on 17.02.2020, and reiterated through further representations and legal notice. The Bench found that the sequence of communications “clearly establish that the appellant had full knowledge of the interim order in force.”

The Court was equally firm in rejecting the plea that subsequent recovery of the disbursed amounts should mitigate the offence. In emphatic terms, the Bench declared, “Once an order of this Court has been violated, the contempt is complete.” Recovery after violation does not obliterate the act of disobedience.

On sentence, the appellant sought leniency on the ground that she had already undergone 19 days of civil imprisonment out of the one-month sentence. The Court refused to dilute the punishment, holding that “considering the nature of the disobedience and the need to maintain respect for court orders, the sentence imposed… cannot be said to be excessive or unjust.”

Concluding that the learned Single Judge had rightly found wilful disobedience, the Division Bench dismissed the appeal and directed the appellant to undergo the remaining period of civil imprisonment.

The ruling sends a strong message to public authorities that judicial orders, especially interim directions safeguarding public funds, are not advisory in nature. Administrative convenience, internal interpretation, or reliance on revenue records cannot justify deviation from a subsisting court mandate.

Date of Decision: 23/02/2026