Can the Supreme Court exercise its inherent contempt jurisdiction to enforce compliance of its judgment by directing a non-party governmental department to refund statute-barred stamp value?

LawSikho
January 6, 2026
Category: Supreme Court of India

Summary

Category	Data
Court	Supreme Court of India
Case Number	CONMT.PET.(C) No.-000703-000704 ‑ 2025
Diary Number	47816/2025
Judge Name	HON’BLE MR. JUSTICE VIKRAM NATH
Bench	HON’BLE MR. JUSTICE VIKRAM NATH HON’BLE MR. JUSTICE SANDEEP MEHTA
Precedent Value	Affirms that Supreme Court directions bind all state instrumentalities and can be enforced through contempt jurisdiction
Overrules / Affirms	Affirms existing inherent-jurisdiction principles
Type of Law	Contempt jurisdiction; inherent powers of the Supreme Court; stamp law
Questions of Law	Whether a contempt petition is maintainable against a non-party governmental department for non-compliance with an SC order Whether a statutory limitation on stamp refunds can override a Supreme Court directive
Ratio Decidendi	The Court held that its inherent contempt jurisdiction extends to all state instrumentalities and that non-party departments may be impleaded when necessary to secure compliance with its judgments. It ruled that statutory provisions (Rule 218 of the U.P. Stamp Rules, 1942) limiting refunds do not override a binding Supreme Court directive. The bona-fide interpretation of a statute and an unconditional apology by the State do not preclude the issuance of a compliance direction. Consequently, the Uttar Pradesh Registration Department was directed to refund Rs. 3,99,100 upon return of the expired stamp papers within two months.
Judgments Relied Upon	Dharmendra Sharma v. Agra Development Authority, (2025) 1 SCC 422
Logic / Jurisprudence / Authorities Relied Upon	Inherent jurisdiction of the Supreme Court to enforce its directives against all state actors; binding effect of apex-court orders
Facts as Summarised by the Court	Respondent No. 1 refunded deposit and interest but returned expired stamp papers instead of refunding Rs. 3,99,100. Petitioner’s application to the Stamp Department was rejected under Rule 218, U.P. Stamp Rules, 1942, on limitation grounds. Petitioner filed contempt petitions; the Court impleaded the State as respondent and received an apology with a bona-fide interpretation.

Practical Impact

Category	Impact
Binding On	All State departments, registration and stamp authorities, and subordinate courts
Persuasive For	High Courts, other Central and State governments
Follows	Dharmendra Sharma v. Agra Development Authority, (2025) 1 SCC 422

What’s New / What Lawyers Should Note

Supreme Court’s inherent contempt jurisdiction can reach non-party government departments when they are duty-bound to implement its orders.
Statutory time-bars (e.g., eight-year limit under Rule 218, U.P. Stamp Rules) cannot override a binding Supreme Court directive.
A bona-fide statutory interpretation and unconditional apology by the State do not shield it from contempt directives.
The court may implead non-party state instrumentalities mid-proceedings to secure effective relief.
Directions to refund stamp value can be obtained even after physical stamps have expired, upon return of those stamps.

Summary of Legal Reasoning

The petitioner alleged non-compliance with the Supreme Court’s 6 September 2024 order requiring refund of non-judicial stamp cost.
The Stamp Department rejected refund applications under Rule 218, U.P. Stamp Rules, citing an eight-year limitation and a December 2018 final filing cut-off.
The Court granted leave to implead the State of Uttar Pradesh as respondent for securing compliance.
The State conceded it acted on a bona-fide interpretation, tendered an apology, and undertook to comply.
Relying on its inherent jurisdiction, the Court held that its directives bind all state instrumentalities and that statutory bars cannot defeat a Supreme Court order.
A two-month deadline was fixed for refund of Rs. 3,99,100 upon return of stamp papers; contempt petitions against respondent No. 1 were closed.

Arguments by the Parties

Petitioner

Respondent No. 1 returned only expired stamp papers and not the Rs. 3,99,100 value as directed.
Stamp Department’s refusal was contrary to the Supreme Court’s order.

State of Uttar Pradesh (Respondent No. 2)

Rejection based on Rule 218 U.P. Stamp Rules, 1942, prescribing an eight-year refund limitation and a cut-off date of 20 December 2018.
Action taken bona fide; tendered unconditional apology; duty-bound to implement Supreme Court directions.

Factual Background

Parties had earlier obtained a Supreme Court order directing the Agra Development Authority to refund deposits with interest and pay a compensation of Rs. 15 lakhs plus refund non-judicial stamp papers worth Rs. 3,99,100. The Authority refunded the deposit, interest and compensation but returned only the expired stamp papers. The petitioner’s applications for stamp-value refund to the Registration Department were rejected on limitation grounds, leading to these contempt petitions.

Statutory Analysis

Rule 218, U.P. Stamp Rules, 1942 (as amended):
- Physical non-judicial stamp papers refundable within eight years of purchase.
- Final date for refund applications one year after the 20 December 2017 amendment (i.e., by 20 December 2018).
Judgment clarifies that these provisions cannot override a binding Supreme Court directive.

Dissenting / Concurring Opinion Summary

No separate dissenting or concurring opinions recorded.

Procedural Innovations

Permissive impleadment of a non-party state department in contempt proceedings to secure compliance with a prior Supreme Court order.

Alert Indicators

✔ Precedent Followed – Existing inherent jurisdiction principles affirmed and applied to non-party state instrumentalities.