Contempt Jurisdiction | Non-Compliance Of Writ Court Order Cannot Be Alleged If Petitioner Fails To Meet Conditions Precedent Stipulated By Supreme Court: Uttarakhand High Court

"The Supreme Court clarified that the relaxation granted by it was a one-time measure and would not be treated as a precedent." Uttarakhand High Court, in a ruling dated 29 September 2026, held that contempt proceedings cannot be sustained where the petitioner fails to satisfy the essential factual prerequisites prescribed by the Supreme Court for granting academic relief.

A bench of Hon’ble Mr. Justice Pankaj Purohit observed that when an order relies upon a "one-time measure" relaxation, the court must strictly ensure that the beneficiary meets the cut-off dates mandated by the Apex Court.

The contempt petitions were filed by students and the Shivalik Institute of Ayurveda and Research, alleging willful disobedience of a writ court’s order dated 07.05.2026. The writ court had directed the University to treat certain student admissions as regular and permit them to appear for back-paper examinations. The petitioners contended that the University had failed to comply with these directions, thereby necessitating the invocation of contempt jurisdiction.

The primary question before the court was whether the respondents were in contempt for failing to regularize the students' admissions in light of the directions given by the writ court. The court was further tasked with determining whether the petitioners met the mandatory cut-off date of 15.10.2019, as stipulated in the judgment of the Supreme Court in Union of India vs. Federation of Self-Financed Ayurvedic Colleges Punjab and Others.

Court's Observations on Scope of Relief

The Court meticulously examined the compliance affidavits filed by the University, which categorically stated that the petitioners were not admitted to the institution on or before the crucial date of 15.10.2019. The University maintained that the relief sought was contingent upon admissions having been finalized by that specific date, pursuant to the one-time measure allowed by the Apex Court.

Strict Adherence to Cut-off Dates

The Bench emphasized that the writ court’s order was predicated on the Supreme Court's mandate, which had provided a relaxation for students admitted prior to 15.10.2019 due to the peculiar circumstances of that academic year. The court noted that the Supreme Court had explicitly cautioned that this relaxation was a "one-time measure" and was not to be treated as a precedent.

Lack of Contempt Findings

Upon review of the supplementary affidavits, the High Court found that the petitioners could not establish that their admissions met the requisite temporal criteria. Since the petitioners failed to fulfill the conditions precedent for the benefit of regularization, the respondent-University's refusal to grant the relief did not constitute a willful violation or defiance of the court’s order.

"The Supreme Court held that Section 22 of the Indian Medicines Central Council Act, 1970, which empowers the Central Council to prescribe minimum standards of education in Indian Medicine, is wide enough to enable the Council to provide for NEET examination."

The court concluded that no case for contempt was made out as the order of the writ court could not be extended to students who fell outside the strict parameters established by the Supreme Court’s 2020 judgment. Consequently, the contempt petitions were dismissed, and all pending applications were disposed of accordingly.

Date of Decision: 29 September 2026