K Janardhan Reddy Vs G Sai Prasad IAS — Contempt of Court | Andhra Pradesh HC (2026)

K Janardhan Reddy Vs G Sai Prasad IAS — Contempt of Court | Andhra Pradesh HC (2026)

What the court decided

AI extract

Outcome

No substantive relief; the contempt case was held not maintainable and closed as time-barred under Section 20 of the Contempt of Courts Act, 1971; miscellaneous petitions, if any, also stand closed; the petitioner was left free to initiate appropriate proceedings for his grievance; no costs.

Issue for consideration

Whether the contempt case, filed on 26.12.2025 beyond the one-year limitation period prescribed by Section 20 of the Contempt of Courts Act, 1971 (deadline 15.06.2025), is maintainable. +1 more

Court's answer

Computing limitation: the orders dated 11.12.2023 were served on 04.05.2024 with a six-week compliance period, making implementation due on or before 15.06.2024; consequently, under Section 20 of the Contempt of Courts Act, 1971 (one year from the contemptuous act), the contempt case had to be filed on or before 15.06.2025, whereas it was filed on 26.12.2025.

Ratio / Principle

Any delay in invoking the jurisdiction of the Court under Section 20 of the Contempt of Courts Act, 1971 cannot be condoned; the Act must be applied strictly, and the general condonation principles (liberal, pragmatic, reasonable allowance of delay) are not applicable to Section 20.

Key takeaways

Since the contempt case was filed on 26.12.2025, beyond the one-year limitation expiring on 15.06.2025 under Section 20, it is not maintainable and is accordingly closed; the petitioner remains free to pursue appropriate proceedings in respect of his grievance, with no order as to costs.ratio¶35

Detailed headnote1 paragraphs

Contempt of Courts Act, 1971 — Section 20 — limitation for actions for contempt — delay cannot be condoned — maintainability. A contempt case (CC No. 4200 of 2025) alleging willful disobedience of the orders dated 11.12.2023 passed in W.P.No.17798 of 2023 — where the orders were served on the respondents on 04.05.2024 and a six-week compliance period made implementation due by 15.06.2024 — was filed only on 26.12.2025. Section 20 permits initiation of contempt proceedings within one year of the alleged contempt, i.e., on or before 15.06.2025. Held (Venkateswarlu Nimmagadda, J., 06.01.2026): delay in invoking jurisdiction under Section 20 cannot be condoned; the liberal, pragmatic condonation principles applicable to ordinary delay petitions do not apply since the Act must be applied in its strict sense; the contempt case is therefore not maintainable and is closed, while leaving the petitioner free to pursue appropriate proceedings; miscellaneous petitions, if any, also closed; no costs.

APHC010710942025

IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction)

[3329]

TUESDAY,THE SIXTH DAY OF JANUARY TWO THOUSAND AND TWENTY SIX

PRESENT

THE HONOURABLE SRI JUSTICE VENKATESWARLU NIMMAGADDA CONTEMPT CASE NO: 4200/2025

Between:

K JANARDHAN REDDY, S/O KOTA SANKAR REDDY, AGED ABOUT 55 YEARS R/O D NO 26-1-945, B.V NAGAR, NELLORE SPSR NELLORE DISTRICT.

...PETITIONER

AND

G SAI PRASAD IAS, PRINCIPAL SECRETARY, WATER RESOURCES DEPARTMENT, AP SECRETARIAT, VELAGAPUDI, AMARAVATI.

PEEYUSH KUMAR I A S, PRINCIPAL SECRETARY, AP FINANCE AND PLANING DEPARTMENT, AP SECRETARIAT, VELAGAPUDI, AMARAVATI.

S DESE NAIK, SUPERINTENDENT ENGINEER, WATER RESOURCES DEPARTMENT, IRRIGATION CIRCLE AND COMMAND DEVELOPMENT, NELLORE, SPSR NELLORE DISTRICT.

S DESE NAIK PERSON IN CHARGE, EXECUTIVE ENGINEER, WATER RESOURCES DEPARTMENT, NELLORE CENTRAL DIVISION, NELLORE, SPSR NELLORE DISTRICT.

...CONTEMNOR(S):

Petition under Sections 10 to 12 of Contempt of Courts Act 1971 praying that in the circumstances stated in the affidavit file herein the High Court may be pleased to pleased to issue summons to the Respondents upon due enquiry may be pleased to punish the Respondents under section 10 to 12 of Contempt of Courts Act, 1971, for their willful disobedience of order dated

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11.12.2023 passed in Writ Petition No. 17798 of 2023 on the file of this Hon'ble court and pass

Counsel for the Petitioner:

1.SIVAPRASAD REDDY VENATI

Counsel for the Contemnor(S):

The Court made the following:

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THE HON’BLE SRI JUSTICE VENKATESWARLU NIMMAGADDA CONTEMPT CASE NO: 4200/2025

ORDER:

This contempt case is filed against the respondents for willful disobedience of the orders dated 11.12.2023 passed by this Court in W.P.No.17798 of 2023.

Heard the learned counsel for the petitioner.

Learned counsel for the petitioner submits that this contempt case is filed alleging that orders of this Court dated 11.12.2023 are not complied with as directed by this Court.

On perusal of the petition filed by the petitioner that the orders of this Court were served upon the respondents on 04.05.2024. While disposing of the Writ Petition, this Court fixed six (06) weeks time period from the date of receipt of copy of the order, for release of the amount in favour of the petitioner and to comply with the orders of this Court dated 11.12.2023. If that is so, the order dated 11.12.2023 should be implemented on or before 15.06.2024. As per Section 20 of the Contempt of Courts Act, 1971 the contempt should be filed within a period of one year from the date when the contemptuous act said to have been committed by the respondents. Therefore, the contempt case should be filed on or before 15.06.2025, but admittedly this contempt case is filed on 26.12.2025 without assigning any reasons for the delay caused at sworn affidavit filed in support of the contempt case. It is settled principle of law

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that any delay in invoking jurisdiction of this Court under Section 20 of the Act, cannot be condoned, since the Act should be applied in strict sense. Therefore, the general principle for condonation of delay i.e., the court must be liberal, pragmatics and reasonable in allowing delay petitions is not applicable under Section 20 of the Act.

For better understanding Section 20 of the Contempt of Courts Act, is extracted hereunder:

“ 20. Limitation for actions for contempt .—No court shall initiate any proceedings of contempt, either on its own motion or otherwise, after the expiry of a period of one year from the date on which the contempt is alleged to have been committed.”

In view of the reasons stated above and on perusal of the Section 20 of the Act, 1971, the contempt case is not maintainable. Accordingly, the contempt case is closed. However, if the petitioner has any grievance, he can proceed with the same by initiating appropriate proceedings. No order as to costs.

Consequently, Miscellaneous Petitions, if any, pending in the contempt case shall stand closed.

________________________________ VENKATESWARLU NIMMAGADDA, J

06.01.2026 TPS

5

157

HON’BLE SRI JUSTICE VENKATESWARLU NIMMAGADDA

(closed)

CONTEMPT CASE NO:4200 /2025

06.01.2026 TPS