Court allowed application for impleadment of new incumbent Secretary of School Education Department in contempt petition, deemed essential for effective adjudication due to transfer of previous officer.
Application for impleadment of Ms. Asangla Imti as Respondent No. 4 allowed.
This page shows the compact analysis of this judgement. The full analysis — procedural history, issue-by-issue holdings with ratio and obiter, advocates, and paragraph-level evidence for every claim — is being added to the record in batches and will appear here when this judgement has been through it.
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GAHC020007902026
THE GAUHATI HIGH COURT (HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH) KOHIMA BENCH
Case No. : I.A.(Civil)/223/2026
SHRI IMKONGWAPANG
S/O TIAKABA, R/O UNGMA VILLAGE, MOKOKCHUNG, NAGALAND
VERSUS
SHRI SENTIYANGER IMCHEN, IAS AND 2 ORS THE CHIEF SECRETARY TO THE GOVT. OF NAGALAND
2:SMTI. KEVILENO ANGAMI THE COMMISSIONER AND SECRETARY DEPARTMENT OF SCHOOL EDUCATION NAGALAND KOHIMA
3:SHRI SHASHANK PRATAP SINGH IAS THE PRINCIPAL DIRECTOR DEPARTMENT OF SCHOOL EDUCATION NAGALAND KOHIM
Advocate for the Petitioner : TOSHI O. LONGKUMER,
Advocate for the Respondent : ,
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Linked Case : COP(C)/9/2026 SHRI IMKONGWAPANG S/O TIAKABA R/O UNGMA VILLAGE MOKOKCHUNG NAGALAND
VERSUS SHRI SENTIYANGER IMCHEN IAS AND 2 ORS THE CHIEF SECRETARY TO THE GOVT. OF NAGALAND KOHIMA 2:SMTI. KEVILENO ANGAMI COMMISSIONER AND SECRETARY DEPARTMENT OF SCHOOL EDUCATION NAGALAND KOHIMA 3:SHRI SHASHANK PRATAP SINGH IAS THE PRINCIPAL DIRECTOR DEPARTMENT OF SCHOOL EDUCATION NAGALAND KOHIMA -----------Advocate for : TOSHI O. LONGKUMER Advocate for : N. ANGAMI(C-1) appearing for SHRI SENTIYANGER IMCHEN IAS AND 2 ORS
BEFORE HONBLE MRS JUSTICE HELEN DAWNGLIANI
O R D E R
15.09.2026
Ms. Esther Chakre, learned counsel appeared on behalf of the Petitioner.
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2. The instant application has been filed for impleadment of Smti. Asangla Imti, Commissioner & Secretary, Department of School Education, Nagaland as Respondent No. 4 in Contempt Petition [COP(C)/9/2026].
3. The learned counsel for the Petitioner submitted that at the time of filing the instant contempt petition, Smti. Kevileno Angami, Respondent No. 2 was holding the post of Commissioner & Secretary, Department of School Education, Nagaland. However, the said incumbent has been transferred to Health & Family Welfare Department vide the Notification PAR-4/6/2020/A dated 04.08.2026 and is replaced by Smti. Asangla Imti as the Commissioner & Secretary, Department of School Education, Nagaland. According to the learned counsel, due to the change in incumbent of the School Education Department it has become imperative to implead the new incumbent as party Respondent to the instant Contempt Petition. The learned counsel, therefore, submitted that she may be allowed to add Smti. Asangla Imti, Commissioner & Secretary, Department of School Education, Nagaland as Respondent No. 4 which is necessary for effective and complete adjudication of the contempt petition.
4. The Contempt Petition is directed against an individual for the willful and deliberate violation of Court’s order even though the violation may have been in the course of performance of official duty. In the case at hand, in order to fully adjudicate the contempt petition impleadment of Respondent No. 4 who is the present incumbent to the concerned Department is found to be essential. I find force in the submission made by the learned counsel.
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5. It is made clear that the impleadment of the present incumbent is necessitated only on account of change of incumbency and for effective adjudication, and shall not, by itself, be construed as an expression of opinion on the merits of the allegations made in the contempt petition.
6. The application for impleadment of Ms. Asangla Imti as Respondent No. 4 is allowed and the application is disposed.
JUDGE
Comparing Assistant
1 issue framed by the court
Whether the new Commissioner and Secretary of School Education Department should be impleaded in an ongoing contempt petition due to a change in incumbency.
2 provisions across 2 enactments
SHRI IMKONGWAPANG
SHRI SENTIYANGER IMCHEN
SMTI. KEVILENO ANGAMI
SHRI SHASHANK PRATAP SINGH
SMTI. ASANGLA IMTI
HELEN DAWNGLIANI
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
