Facts:
The contempt petitions arose from alleged non-compliance with Supreme Court orders related to the issuance of Transferable Development Rights (TDR) certificates for land acquired in Bengaluru for road widening. Despite clear court orders from 2014, 2022, and 2024, the Karnataka government and its agencies delayed implementation, citing financial hardship and technical disputes over land valuation and issuance procedures.
Contentions of the Appellants:
The petitioners claimed willful disobedience of Supreme Court orders, arguing that despite directives to issue TDR certificates, the government failed to comply. They cited undue delays, intentional misinterpretation of court rulings, and undervaluation of the acquired land. They sought contempt action against responsible officials.
Contentions of the Respondents:
The Karnataka government and associated agencies claimed compliance through partial steps like issuing notices and government orders. They cited administrative complexities, conflicting legal interpretations, and procedural delays. They asserted that no deliberate defiance occurred and tendered an unconditional apology for any perceived non-compliance.
Issues:
- Whether the orders of the Supreme Court dated 21.11.2014, 17.05.2022, and 19.03.2024 were willfully disobeyed.
- Whether the respondents’ actions amounted to intentional non-compliance under the Contempt of Courts Act, 1971.
- Whether the issued TDR certificates complied with prescribed legal standards.
Observations/Findings by the Supreme Court:
The Court found clear, willful disobedience of its orders. It criticized the state for delaying TDR issuance through excuses like financial hardship and incorrect land valuation. The Court rejected the state’s justification of administrative complexities, noting that the authorities failed to act for nearly a decade. It dismissed the undervalued land assessments and directed compliance with full market value as per the Karnataka Stamp Act, 1957.
Principle of the Case:
The principle established is that state authorities cannot evade compliance with judicial orders by citing administrative or financial difficulties. Willful disobedience, even if veiled behind procedural delays, constitutes contempt. Judicial mandates must be obeyed in letter and spirit, with no room for creative reinterpretation.
Final Order:
The Supreme Court held the respondents guilty of contempt and directed immediate issuance of TDR certificates as per correct market valuation. It granted a final six-week window for compliance, warning of stricter consequences for further delays.
Impact on Public Law and Order:
This judgment reaffirms the binding nature of judicial decisions, deterring governmental authorities from defying court orders. It strengthens the rule of law by ensuring that even powerful state institutions remain accountable. The ruling discourages bureaucratic inertia and enforces timely compliance with legal directives.
Case Citation:
Supreme Court of India, Chaduranga Kanthraj Urs & Others vs. State of Karnataka & Others, Contempt Petition (Civil) No. 688 of 2021 in Civil Appeal No. 3310 of 1997, Judgment dated December 10, 2024.
