The Supreme Court disposed of contempt petitions, affirming wilful disobedience of prior orders dated November 21, 2014, May 17, 2022, and December 10, 2024, regarding the issuance of DRCs/TDRs. The Court rejected attempts to re-examine previously decided issues or impose new conditions, emphasizing its limited contempt jurisdiction. DRCs/TDRs are to be released to complainants upon filing an undertaking, with the State retaining a first charge on any future compensation from civil appeals
Facts Of The Case:
This case involves contempt petitions filed due to alleged wilful disobedience of court orders dated November 21, 2014, May 17, 2022, and March 19, 2024. The Supreme Court, in a judgment dated December 10, 2024, found the contemnors guilty of wilful non-compliance despite purported compliance affidavits, which were rejected. The contemnors were held responsible for delaying the re-issuance of DRCs/TDRs for over 10 years and were mulcted with costs of Rs. 1,00,000/- to each complainant. Subsequently, further attempts were made to delay the release of DRCs/TDRs, including filing an application to prevent their handover until pending civil appeals were disposed of and review petitions were heard. The Court reiterated that its jurisdiction was limited to examining compliance with its prior orders. Despite earlier incorrect and improper deposits of DRCs/TDRs, the contemnors eventually deposited them in the individual names of those from whom land had been acquired, following an undertaking made in court. The Court dismissed the State’s apprehension about recovering the value of DRCs/TDRs if complainants did not succeed in civil appeals, stating that such conditions would amount to tweaking previous orders. The Court directed the rectification of one TDR/DRC name and ordered the handover of all deposited DRCs/TDRs to the respective complainants upon filing an undertaking that their receipt would be subject to the outcome of pending civil appeals, with the State having a first charge on any compensation awarded
Procedural History:
The procedural history of this case reveals a protracted legal battle spanning over a decade, marked by repeated non-compliance with judicial orders. The matter originated from Civil Appeal Nos. 3309-3310 of 1997, concerning land acquisition disputes under the Bangalore Palace (Acquisition and Transfer) Act, 1996 (BPAT Act). Multiple contempt petitions were filed between 2013 and 2025 (notably CP Nos. 188-189/2013, 237/2014, 103-104/2025, and 129/2025) alleging wilful disobedience of Supreme Court orders dated 21.11.2014, 17.05.2022, and 19.03.2024. These orders directed the issuance of Transferable Development Rights (TDRs) and Development Rights Certificates (DRCs) to affected landowners. On 10.12.2024, the Court held the contemnors (including state officials) guilty of deliberate non-compliance, imposed costs of ₹1 lakh per petitioner, and granted a final six-week window for compliance. Despite this, the contemnors persisted in delaying tactics, including filing an interlocutory application (IA No. 120858/2025) seeking to withhold TDRs pending civil appeals. The Court rejected this attempt, reiterating that contempt proceedings could not be used to relitigate substantive issues. By May 2025, after multiple hearings and affidavits, the Court ordered the rectification and release of TDRs/DRCs to petitioners, contingent on undertakings that their receipt would be subject to the outcome of pending civil appeals. The case underscores the judiciary’s frustration with systemic delays and the state’s attempts to circumvent compliance through procedural maneuvers.
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Court Observation:
The court made several critical observations in its judgment, emphasizing the contemnors’ persistent defiance of judicial orders. It noted that the state authorities had engaged in deliberate stalling tactics for over a decade, including filing compliance affidavits with incorrect or incomplete TDRs/DRCs, despite clear directives in the 2014, 2022, and 2024 orders. The bench strongly deprecated the contemnors’ attempts to use procedural maneuvers—such as interlocutory applications and pending civil appeals—to justify non-compliance, stating that such actions amounted to a strategic and willful obstruction of justice. The court clarified that contempt proceedings were not an avenue to revisit the merits of the case or modify earlier orders, and it rejected the state’s argument to withhold TDRs pending the outcome of related appeals. Instead, it directed the immediate release of corrected TDRs/DRCs to the petitioners, requiring only a simple undertaking to safeguard the state’s interests in case of future adverse rulings. The judgment underscored the principle that court orders must be implemented in letter and spirit, without exception, and highlighted the judiciary’s intolerance for institutional delays that undermine the rule of law.
Final Decision & Judgement:
The Supreme Court disposed of the contempt petitions, including Contempt Petition (C) Nos. 103, 104, and 129 of 2025, along with all pending applications. The Court ordered that the TDRs/DRCs already deposited by the State be handed over to the respective complainants or their authorized representatives forthwith. This handover is contingent upon the complainants filing an undertaking by way of an affidavit before the Court, stating that the receipt of the DRCs/TDRs would be subject to the outcome of the pending civil appeals. To allay the State’s apprehension, it was clarified that in the event the contemnors do not succeed in the pending civil appeals and any compensation is awarded to the complainants in those proceedings, the State shall have the first charge or claim over such determined or awarded compensation.Furthermore, the Court specifically ordered the rectification of the TDRs/DRCs deposited in the name of “Shrimati Indrakashi Tripurawasni” in CP No. 103 of 2025 to “Shrimati Indrakshi Devi” only, with the corrected documents to be deposited in the Court within four weeks. The Court also directed that the costs, which had been deposited, be paid to the respective complainants as previously ordered on December 10, 2024. The Court emphasized that any note made under the TDRs/DRCs would be of no consequence or irrelevant, and the transaction of DRCs/TDRs by the contemnors would be without prejudice to the rights of both parties, with statutory embargos having no bearing.
Case Details:
Case Title: CHADURANGA KANTHARAJ URS vs. S.V. RANGANATH AND ORS. Citation: 2025 INSC 762 Civil Appeal No(s).: 3309-3310 OF 1997 Date of Judgement: May 22, 2025 Judges/Justice Name: M.M. SUNDRESH and ARAVIND KUMAR