One Bench Cannot Overrule Another’s Finding in the Same Court: Supreme Court Slams Delhi High Court for Overturning Contempt Ruling Without Appeal

“When a Coordinate Bench Finds Someone Guilty of Contempt, Another Judge Can’t Sit in Appeal Over It — That’s Judicial Impropriety” —  In a resounding affirmation of judicial discipline and procedural finality, the Supreme Court of India, on April 23, 2025, in Rajan Chadha & Anr. v. Sanjay Arora [Civil Appeal arising out of SLP (C) No. 17013 of 2024], quashed a Delhi High Court judgment that had reversed a contempt finding without following the due appellate process. The Court held that one Single Judge of a High Court cannot re-examine and reverse the findings of contempt made by another coordinate Judge.

Justice B.R. Gavai, writing for the Bench with Justice Augustine George Masih, made it clear: “The order of the learned Single Judge of the High Court by holding that the Respondent had not committed contempt amounts to sitting in an appeal over the order passed by the coordinate Bench.”

Arbitration, EMIs, and Contempt

The matter arose from a corporate MoU executed in 2019 between Rajan and Rajiv Chadha (Appellants) and Sanjay Arora (Respondent) for transferring shareholding in “RBT Pvt. Ltd.”. Arora, having taken over control, was contractually obligated to pay EMIs on a company loan, failing which the house of one appellant — used as collateral — was at risk.

After the matter moved to arbitration, the arbitrator directed Arora to continue paying EMIs. When he defaulted, the appellants moved the Delhi High Court in contempt, alleging disobedience of both the High Court’s earlier order and the arbitrator’s directive.

On 5 December 2023, a Single Judge of the High Court found Arora guilty of contempt, granting him 4 weeks to purge the contempt or file an affidavit explaining why punishment should not be imposed.

However, following a roster change, another Single Judge heard the matter afresh, and on 3 July 2024, discharged the notice and dismissed the contempt petition, holding there was no wilful disobedience.

Supreme Court: “Once Guilt Is Found, Only Punishment Can Be Considered — Not a Reversal of Guilt”

The Supreme Court unequivocally held that the second Single Judge acted beyond jurisdiction:

“The matter was postponed only for enabling the Respondent to purge the contempt or to explain why he should not be punished. Revisiting the issue of guilt was not permissible.”

“If the Respondent believed the finding of contempt was erroneous, his only remedy was to appeal under Section 19 of the Contempt of Courts Act, 1971 — not to seek a rehearing from another Judge of the same court.”

The Court characterized the later order as: “Not only in excess of jurisdiction but also contrary to the well-settled principles of judicial propriety.”

On Judicial Discipline and Coordinate Benches

Quoting from its own reasoning, the Bench emphasized: “When one Judge of the same Court has taken a particular view holding the Respondent guilty of contempt, another Judge could not have come to a finding that the Respondent was not guilty of contempt.”

It reiterated that judges cannot function in review or appeal over decisions by coordinate benches, and to do so undermines both certainty of adjudication and institutional integrity.

Restoring procedural correctness and the rule of law, the Supreme Court:

• Quashed the Delhi High Court’s judgment dated 3 July 2024, and

• Remitted the case back to the High Court to proceed from the stage of its earlier order dated 5 December 2023, where the Respondent had already been found guilty.

“The only question now is whether the Respondent has purged the contempt or should be punished under the Contempt of Courts Act.”

By disallowing judicial “review” by rotation, this ruling reasserts that consistency and respect for coordinate decisions are not just decorum, but doctrine.

Date of Decision: April 23, 2025