Tata Motors Finance Motors vs Bharat Patat — Bombay HC (2026) — LawSathi Research

Tata Motors Finance Motors vs Bharat Patat — Bombay HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Cause-title amendment allowed (Petitioner-Company renamed 'Tata Capital Limited'); draft amendment taken on record and marked 'X', to be carried out within one week, reverification dispensed with; consideration of the contempt allegation deferred and the matter stood over to 13th January, 2026.

Issue for consideration

Whether the Respondents' conduct in not complying with paragraph 5 of the order dated 12th September, 2025 (failure to deposit Rs. 67 lakhs) qualifies as contempt of this Court. +1 more

Court's answer

On a prima facie view, the Court does not find that the alleged breach (non-compliance with paragraph 5 of the order dated 12th September, 2025) would amount to contempt; the final view is reserved, as the Petitioner's counsel was given time to place reliance on legal precedents and the matter was stood over to 13th January, 2026.

Ratio / Principle

The Petitioner is allowed to amend the cause title to change the Petitioner-Company's name from 'Tata Motors Finance Limited' to 'Tata Capital Limited'; the draft amendment is taken on record and marked 'X' for identification, the amendment is to be carried out within one week, and reverification is dispensed with.

Detailed headnote1 paragraphs

Bombay High Court, Commercial Division (Ordinary Original Civil Jurisdiction) — Contempt Petition No. 44 of 2025 in Commercial Arbitration Petition No. 736 of 2024 (Tata Motors Finance Limited v. Bharat Patat), Coram: Arif S. Doctor, J., 6th January, 2026. Interim order: (i) The Petitioner was allowed to amend the cause title, changing the Petitioner-Company's name from 'Tata Motors Finance Limited' to 'Tata Capital Limited' pursuant to a scheme of amalgamation; the draft amendment was taken on record and marked 'X' for identification, the amendment was to be carried out within one week, and reverification was dispensed with. (ii) On the contempt allegation — that the Respondents breached an undertaking to the Court / failed to comply with paragraph 5 of the order dated 12th September, 2025, which had directed deposit of Rs. 67 lakhs in Court within four weeks — the Petitioner's counsel conceded that the order contained no express undertaking ('to be inferred'). The Judge's prima facie view was that such breach would not amount to contempt; time was given to the Petitioner to cite legal precedents and the matter was stood over to 13th January, 2026. No statute or precedent is cited in this excerpt and no merits decision on the contempt question was rendered.

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IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION IN ITS COMMERCIAL DIVISION

CONTEMPT PETITION NO. 44 OF 2025

IN

COMMERCIAL ARBITRATION PETITION NO. 736 OF 2024

Tata Motors Finance Motors ...Petitioner

Versus

Bharat Patat

...Respondent

Mr. Gaurav Jangle a/w Akshita Jain a/w Akshit Vats i/b I.V. Merchant & Co. for Petitioner.

_______ CORAM : ARIF S. DOCTOR, J. DATE : 6th JANUARY, 2026

P.C.

Learned counsel for the Petitioner at the outset tenders a draft amendment by which he seeks to change the name of the Petitioner -Company from ‘Tata Motors Finance Limited’ To ‘Tata Capital Limited’. He submits that this has been pursuant to a scheme of amalgamation.

Given the formal nature of the amendment, the Petitioner is allowed to amend the cause title. The draft amendment is taken on record and marked ‘X’ for identification. Amendment to be carried out within a period of one week from today. Reverification is dispensed with.

After hearing Mr. Jangle learned counsel for the Petitioner at some length and noting that the Contempt Petition alleged breach of an undertaking given by

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the Respondents to this Court, when asked to point out such undertaking, learned counsel for the Petitioner fairly submitted that the Order did not contain any such undertaking and the same was to be inferred.

Mr. Jangle, however, submitted that the conduct of Respondents would still qualify as being contemptuous, because the Respondents have not complied with the directions of this Hon’ble Court, more particularly in paragraph no. 5 of the order dated 12th September, 2025, which reads thus;

“5. The only contention raised by Mr Sinha, Learned Counsel appearing for the Respondent today is that the net value outstanding is not Rs.75,75,473.86 but curiously it is his contention that in respect of two loan accounts the amount is Rs.38 lakhs and Rs. 29 Lakhs in respect of the third account. Thus it is his contention that today in respect of these three accounts, there is an amount of approximately Rs. 67 Lakhs that is due and payable. Hence, since I am considering the matter at the interim stage, the Respondent is directed to deposit an amount Rs.67 Lakhs. As admitted today in Court by Learned Counsel appearing for the Respondent has been due and payable. Let that amount be deposited in Court within a period of four weeks from today.”

In my prima facie view, I do not find that such breach would amount to contempt, however, learned counsel seeks time to place reliance upon legal precedents/ in support of his contention.

At his request stand over to 13th January, 2026 . High On Board.

[ARIF S. DOCTOR, J.]

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