Introduction:

The Punjab & Haryana High Court recently ruled that Lok Adalat does not constitute a court under the Contempt of Courts Act, and its awards, if violated, do not give rise to contempt proceedings. This decision was delivered by a division bench comprising Justice Sureshwar Thakur and Justice Kirti Singh while allowing an appeal challenging a single bench’s order that held the respondents liable for contempt. The case involved land acquisition proceedings in Kurukshetra, where the Permanent Lok Adalat had resolved the dispute based on an undertaking given by the Haryana Government. The petitioner alleged a breach of this undertaking, leading to the filing of a contempt plea. However, the division bench concluded that contempt jurisdiction cannot be exercised over Lok Adalat’s orders, citing the Supreme Court judgment in Brajnandan Sinha vs. Jyoti Narain [AIR 1956 SC 66]. The division bench further highlighted procedural lapses in the single judge’s order, including the failure to frame charges or consider extenuating circumstances. Consequently, the court set aside the single judge’s order and discharged the authorities.

Arguments of Both Sides:

The appellants, represented by Mr Ankur Mittal, Additional Advocate General for Haryana, argued that Lok Adalat is not a court within the meaning of the Contempt of Courts Act, as it lacks judicial authority to punish for contempt. They relied on Brajnandan Sinha vs. Jyoti Narain to assert that the awards of Lok Adalats are not enforceable through contempt proceedings. They further contended that the single bench failed to follow due process by not framing charges or allowing the appellants to explain or justify their actions. They submitted that the alleged violation of the undertaking was based on an administrative action and did not constitute contempt.

The respondent, represented by Mr Nitin Verma, contended that the breach of the undertaking given before the Lok Adalat amounted to interference with the administration of justice, making the respondents liable for contempt. The respondent argued that the authorities had acted contrary to their commitment by failing to exclude the land from acquisition and subsequently issuing orders against the petitioner’s interests. The respondent emphasized that the single bench correctly held the authorities accountable for their actions, which undermined the sanctity of the undertaking and the Lok Adalat’s award.

Court’s Judgment:

The division bench meticulously analyzed the submissions and referred to legal precedents to determine whether the actions of the authorities amounted to contempt of court. The court observed that Lok Adalat, though an alternative dispute resolution mechanism, does not have the trappings of a court under the Contempt of Courts Act. Citing the Supreme Court’s judgment in Brajnandan Sinha vs. Jyoti Narain, the bench emphasized that the orders or awards of Lok Adalats cannot be enforced through contempt proceedings. The court further noted that the single judge had acted arbitrarily by not framing charges or providing the respondents with an opportunity to present their defence.

The division bench underscored that contempt jurisdiction should be exercised with caution and not in a slipshod or arbitrary manner. It highlighted that the single judge failed to consider extenuating circumstances or procedural safeguards, such as framing charges and evaluating evidence before holding the respondents guilty of contempt. The bench also pointed out that the petitioner’s remedy lay in seeking enforcement of the Lok Adalat’s award through appropriate legal channels rather than invoking contempt jurisdiction.

Finding merit in the appeal, the division bench set aside the single judge’s order and discharged the authorities from the contempt proceedings. The judgment reinforced the distinction between judicial and quasi-judicial bodies and the limited scope of contempt jurisdiction under the Contempt of Courts Act.