The Andhra Pradesh High Court held that when parties inform the Court of an out-of-court settlement in a contempt proceeding, the Court may, at its discretion, close the case without further inquiry into the merits or wilfulness of alleged disobedience. This judgment reaffirms the Court’s inherent power to determine appropriate closure procedure where dispute resolution has been achieved between parties. It stands as a binding precedent for subordinate courts on the exercise of discretion in similar circumstances relating to contempt proceedings.
Summary
| Category | Data |
|---|---|
| Case Name | CC/2099/2025 of K RAJESWARI Vs SRI S SATRYANARAYANA IAS |
| CNR | APHC010412182025 |
| Date of Registration | 06-08-2025 |
| Decision Date | 16-10-2025 |
| Disposal Nature | CLOSED NO COSTS |
| Judgment Author | Justice Challa Gunaranjan |
| Court | High Court of Andhra Pradesh |
| Precedent Value | Binding authority on closure/orders in contempt upon out-of-court settlement |
| Type of Law | Contempt of Court—Procedural Disposal |
| Ratio Decidendi |
|
| Facts as Summarised by the Court |
Petitioner sought punishment of respondents under Sections 10–12 & 14 of the Contempt of Courts Act, 1971, alleging wilful disobedience of Court orders dated 20.06.2025. During proceedings, the petitioner’s counsel submitted a letter stating that the dispute had been settled out of Court and sought not to pursue the contempt case. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Andhra Pradesh |
| Persuasive For | Other High Courts; similar superior courts evaluating discretionary closure |
What’s New / What Lawyers Should Note
- Confirms that contempt proceedings may be closed at the discretion of the Court upon written intimation of out-of-court settlement by the petitioner.
- No detailed inquiry into the merits or wilfulness of contempt is required if the petitioning party formally withdraws and settlement is stated.
- Lawyers can utilize this approach to seek efficient closure of contempt proceedings in similar cases where settlement is achieved.
Summary of Legal Reasoning
- The Court observed that the petitioner, through her counsel, submitted a letter to the Registry detailing that the matter had been resolved amicably out of Court.
- On the basis of this communication and absence of objection, the Court exercised its discretion and closed the contempt case, without entering into findings on intentional or wilful disobedience of the order at issue.
- No further directions or costs were imposed; pending miscellaneous petitions related to the case were also deemed closed.
Arguments by the Parties
Petitioner
- Through counsel, stated that the contempt matter had been settled out of Court.
- Expressly sought not to pursue the contempt case further.
Respondent
- No opposition or further submission recorded in the judgment regarding the withdrawal/settlement.
Factual Background
The petitioner, a Deputy Director in the BC Welfare Department, initiated contempt proceedings against two senior department officials alleging wilful non-compliance with a High Court order dated 20.06.2025. While the case was pending, the petitioner’s counsel communicated to the Court by letter that the dispute had been resolved out of Court, and requested closure of the contempt proceedings.
Statutory Analysis
- The judgment was passed under Sections 10–12 and 14 of the Contempt of Courts Act, 1971.
- The Court did not interpret or analyze these sections in detail; disposal rested solely on consent withdrawal following settlement.
Dissenting / Concurring Opinion Summary
No separate dissenting or concurring opinions were recorded in this single-judge bench judgment.
Procedural Innovations
- Recognition of a letter from petitioner’s counsel as sufficient for closure of contempt, streamlining the process for both the court and parties.
- Closure of related miscellaneous petitions in tandem with main contempt disposal upon settlement notification.
Alert Indicators
- Precedent Followed – The Court affirmed established practice allowing discretionary closure of proceedings upon mutual settlement.