Latika Das v. Gyanendra Dev Tripathi, IAS and Anr.
Contempt of Courts Act, 1971 – Section 20 – Limitation for actions for contempt
Case brief
What is this about?
Gauhati High Court, Cont.Cas(C)/393/2025, Latika Das v. Gyanendra Dev Tripathi, IAS & Anr. (District Commissioner, Dhubri), Justice Sanjay Kumar Medhi, order dated 04.08.2025. Contempt petition alleging wilful disobedience of order dated 19.02.2021 in WP(C)/977/2021 (directions to Deputy Commissioner, Dhubri re enquiry into petitioner's claim of accident in a public place) dismissed as barred by limitation under Section 20, Contempt of Courts Act, 1971: one-year limitation computed from expiry of extended 90-day compliance period, petition filed only on 28.07.2025; assurance to petitioner does not extend limitation (penal consequences); counsel's reliance on Pallav Sheth, (2001) 7 SCC 549 held misconceived. Petitioner's advocates: M. Hussain, A.K. Mollah, R.I. Mondal; respondents unrepresented on record.
What did the court decide?
Under Section 20 of the Contempt of Courts Act, 1971, action must be initiated within one year from the date the contempt is alleged to have been committed; since the direction in the order dated 19.02.2021 was to be carried out within an extended period of 90 days, the contempt petition ought to have been filed within one year from the expiry of that extended period, whereas it was filed only on 28.07.2025 — hence the petition is time-barred.