Sh Dharam Pal Vs Project Director Department of Rural Development and Anr. — Delhi HC (2026) — LawSathi Research

Sh Dharam Pal Vs Project Director Department of Rural Development and Anr. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

No fresh final disposal; further directions issued to enforce the recovery certificate: voluntary payment or furnishing of requisite details to respondent no.2 within two weeks, failing which coercive measures by respondent no.2 and possible withholding of salaries of respondent no.1's officials; compliance reporting listed on 26.05.2026 with virtual attendance of respondents.

Issue for consideration

With the recovery certificate against respondent no.1 still unexecuted despite the Court's directions of 11.02.2026, what further steps should the Court direct to secure its execution?

Court's answer

The concerned department is directed to either voluntarily pay the amount which is the subject matter of the recovery certificate, or alternatively forward such details as may be required (bank account details etc.) to respondent no.2 for appropriate action, within two weeks.

Ratio / Principle

If the payment or furnishing of details is not done within two weeks, respondent no.2 is directed to take coercive measures for execution of the recovery certificate against respondent no.1.

Key takeaways

In line with the order dated 11.02.2026, if the recovery certificate remains unexecuted upon expiry of the two-week time limit, the Court shall be constrained to direct that the concerned officials of respondent no.1 not be released their salaries until the certificate is executed.ratio¶18
The matter is listed for reporting compliance on 26.05.2026, and the respondents are directed to join the proceedings virtually on the next date of hearing.ratio¶19

Detailed headnote1 paragraphs

Delhi High Court (Sachin Datta, J.), order dated 28.04.2026 in W.P.(C) 1317/2026 (Sh Dharam Pal v. Project Director, Department of Rural Development and Anr.): A recovery certificate dated 01.07.2025 issued by the Deputy Labour Commissioner, Central District (Annexure P5), execution whereof was the subject matter of the petition, remained unexecuted notwithstanding the Court's order of 11.02.2026 whereby respondents had undertaken expeditious execution and the District Magistrate had undertaken personal attention. The Court directed (i) the concerned department to either voluntarily pay the amount of the recovery certificate or furnish requisite details (including bank account details) to respondent no.2 within two weeks; (ii) failing which respondent no.2 to take coercive measures for execution against respondent no.1; and (iii) warned, in line with the order dated 11.02.2026, that if the certificate remains unexecuted after expiry of the time limit, salaries of concerned officials of respondent no.1 shall not be released until execution. Matter listed for compliance reporting on 26.05.2026; respondents to join virtually. No monetary amount is stated in the order; no statute or precedent is cited.

$~16

IN THE HIGH COURT OF DELHI AT NEW DELHI

- W.P.(C) 1317/2026 SH DHARAM PAL .....Petitioner

Through: Ms. Meghna De, Adv. versus

PROJECT DIRECTOR DEPARTMENT OF RURAL DEVELOPMENT AND ANR .....Respondents Through: Mr. Manashwy Jha, Panel Counsel, GNCTD.

CORAM:

HON'BLE MR. JUSTICE SACHIN DATTA O R D E R % 28.04.2026

The present petition was disposed of vide order dated 11.02.2026, whereby it was directed as under:

“ 1. Learned counsel for the respondents submits, on instructions, that expeditious steps shall be taken for execution of the recovery certificate dated 01.07.2025 issued by the Deputy Labour Commissioner, Central District (Annexure P5) with regard to which the present petition has been filed.

2. It is assured and undertaken that the concerned District Magistrate shall bestow its personal attention to the matter and will ensure compliance. ”

It transpires that despite the aforesaid directions the necessary compliance has not been done and the recovery certificate issued against the respondent no.1 remains unexecuted.

In the circumstances, the following directions are issued:

(i) The concerned department will either voluntarily pay the amount which is the subject matter of the recovery certificate or alternatively will forward such details as may be required, to the respondent no.2 for taking appropriate action (bank account details etc.). Let the same

This is a digitally signed order.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/05/2026 at 12:13:28

be done within a period of two weeks from today.

(ii) In case the aforesaid is not done, the respondent no.2 is directed to take coercive measures for execution of the recovery certificate against the respondent no.1.

(iii) It is made clear that in line with order dated 11.02.2026, in case the recovery certificate remain unexecuted, upon expiry of the aforesaid time limit, this Court shall be constrained to direct that the concerned officials of the respondent no.1 shall not be released their salaries till such time the recovery certificate remain unexecuted.

List for reporting compliance on 26.05.2026.

The respondents are directed to join the proceedings virtually on the next date of hearing.

SACHIN DATTA, J

APRIL 28, 2026/ cl

This is a digitally signed order.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/05/2026 at 12:13:28