Dismissed¶¶31

Smt. Tulsi Rani Samanta and Anr. v. State of West Bengal and Ors.

Calcutta HC11 Feb 2026WPLRT/6/2026

Case brief

AI extract

What is this about?

High Court at Calcutta, WPLRT No. 6 of 2026 (heard and decided February 11, 2026; Sabyasachi Bhattacharyya & Supratim Bhattacharya, JJ.): writ petition dismissed on contest affirming West Bengal Land Reforms and Tenancy Tribunal order dated August 26, 2025 in MA 430 of 2023 arising out of OA No. 1107 of 2020 (LRTT); 2023 contempt application held hopelessly time-barred qua order dated November 29, 2011 in OA No. 1682 of 2010, which also stood given a go-by by the subsequent withdrawn OA with liberty to file fresh representation; April 7, 2022 order contained no direction, so no contempt; no interference, no costs.

What did the court decide?

No relief granted; writ petition dismissed on contest with no order as to costs, affirming the impugned order ¶¶31

Smt. Tulsi Rani Samanta and Anr. Vs State of West Bengal and Ors. — Calcutta HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

No relief granted; writ petition dismissed on contest with no order as to costs, affirming the impugned order

¶¶31

Issue for consideration

Whether the writ court should interfere with the Tribunal's order dated August 26, 2025 (MA 430 of 2023, arising out of OA No. 1107 of 2020) disposing of the contempt application without any penal measure. +1 more

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Court's answer

There is no scope of interference with the impugned order.

¶¶29

Ratio / Principle

Insofar as the order dated November 29, 2011 in OA No. 1682 of 2010 is concerned, the contempt application is hopelessly time-barred.

¶¶24

Key takeaways

In view of the subsequent original application (OA No. 1107 of 2020), wherein the writ petitioners obtained leave to file a fresh representation, the order dated November 29, 2011 passed in the earlier original application was deemed to be given a go-by.ratio¶¶24
Since the order dated April 7, 2022 in OA No. 1107 of 2020 passed no direction at all on the respondent authority and merely permitted withdrawal with liberty to file a fresh representation, no question of violation of that order by the respondent-authorities arises.ratio¶¶25

Detailed headnote1 paragraphs

Constitutional writ (Appellate Side), WPLRT No. 6 of 2026 — dismissed on contest, affirming the order dated August 26, 2025 of the West Bengal Land Reforms and Tenancy Tribunal in MA 430 of 2023, arising out of OA No. 1107 of 2020 (LRTT), by which the petitioners' contempt application of 2023 was disposed of without any penal measure. Held (Sabyasachi Bhattacharyya, J.; Supratim Bhattacharya, J. concurring): (i) the contempt application, insofar as it concerned the order dated November 29, 2011 in OA No. 1682 of 2010 — which had merely directed disposal of the petitioners' representation — was hopelessly time-barred, no contempt application having been filed within limitation; in any event, upon the petitioners obtaining liberty in OA No. 1107 of 2020 to file a fresh representation, the 2011 order was deemed to be given a go-by; (ii) the order dated April 7, 2022 in OA No. 1107 of 2020 passed no direction at all on the respondent authority, only permitting withdrawal with liberty, hence no question of its violation arose; (iii) no contempt having been committed in respect of either order, the Tribunal rightly disposed of the contempt application without penalty, and the writ court found no scope of interference. No order as to costs.

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Form No.J(2)

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IN THE HIGH COURT AT CALCUTTA Constitutional Writ Jurisdiction Appellate Side

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Present : The Hon’ble Mr. Justice Sabyasachi Bhattacharyya &

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The Hon’ble Mr. Justice Supratim Bhattacharya

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WPLRT No. 6 of 2026

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Smt. Tulsi Rani Samanta and another

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-vs-

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The State of West Bengal and others

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For the petitioners : Syed Shamsul Arefin. For the respondent : Mr. Jaharlal De, AGP Mr. Sudipto Panda

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Heard on : February 11, 2026. Judgment on : February 11, 2026.

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: Sabyasachi Bhattacharyya, J.

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On the prayer of learned counsel for the petitioners, we mould

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the relief erroneously sought in the writ petition and deem the writ petition to be a challenge to the order dated August 26,

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2025 passed by the West Bengal Land Reforms and Tenancy

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Tribunal.

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The affidavit-of-service filed in Court today be kept on record.

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In view of both sides being represented before us, we take up the writ petition for hearing.

¶19

By the impugned order, the Tribunal recorded that a contempt application has been filed in the year 2023 in respect of alleged violation of an order dated November 29, 2011 passed in OA No. 1682 of 2010 and an order dated April 7, 2022 passed in OA No. 1107 of 2020, both passed by the Tribunal.

¶20

The brief backdrop of the case is that vide order dated November 29, 2011 in OA No. 1682 of 2010, the alleged contemnor had been directed to dispose of a representation of the writ petitioners within a particular period of time.

¶21

However, no contempt application was filed by the writ petitioners within the limitation period, despite such direction being not been complied with by disposing of such representation.

¶22

Instead thereof, the writ petitioners preferred a fresh application, bearing OA No. 1107 of 2020, ten years later, which was ultimately withdrawn by the writ petitioners with liberty to file a fresh representation before the concerned authority.

¶23

¶24

Thus, insofar as the order dated November 29, 2011 passed in OA No. 1682 of 2010 is concerned, the contempt application is hopelessly time-barred. Moreover, in view of the subsequent original application, where the writ petitioners obtained leave to file a fresh representation, the order dated November 29, 2011 passed in the earlier original application was deemed to be given a go-by.

¶25

In the order dated April 7, 2022 passed in OA No. 1107 of 2020, no direction was passed at all on the respondent authority; rather, the said OA was permitted to be withdrawn with liberty to the writ petitioners to take out a fresh representation. Hence, there does not arise any question of violation of the said order by the respondent-authorities.

¶26

Thus, we completely agree with the observation of the learned Tribunal that there was no contempt committed by the respondent-authorities in respect of either of the orders passed by the Tribunal. In any event, the contempt application was hopelessly time-barred insofar as the order dated November 29, 2011 is concerned.

¶27

Accordingly, the contempt application was rightly disposed of without taking any penal measure.

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We do not find any scope of interference with the impugned

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order.

¶31

Hence, WPLRT No. 6 of 2026 is dismissed on contest, thereby affirming the impugned order dated August 26, 2025 passed in MA 430 of 2023, arising out of OA No. 1107 of 2020 (LRTT).

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There will be no order as to costs.

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Urgent photostat certified copies of this order, if applied for, be supplied to the parties at an early date.

¶34

I agree.

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( Sabyasachi Bhattacharyya, J .)

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( Supratim Bhattacharya, J .)

Smt. Tulsi Rani Samanta and Anr. v. State of West Bengal and Ors.

Case brief

What is this about?

What did the court decide?

Smt. Tulsi Rani Samanta and Anr. v. State of West Bengal and Ors.

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

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Procedural history

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