Dismissed¶40

M.Krishnan v. M.Ambiga, B.E.

Madras HC24 Jun 2026CONT P/2038/2026

Case brief

AI extract

What is this about?

CONT P No. 2038 of 2026; High Court of Judicature at Madras; Justice T. Vinod Kumar; contempt petition maintainability; Section 20 Contempt of Courts Act 1971 one-year limitation; Section 11 Contempt of Court Act 1971; Article 215 Constitution of India; continuing cause of action; S.Tirupathi Rao v. M.Lingamaiah 2024 SCC online 1764; order dated 16.02.2024 in W.P.No.26753 of 2021; TANGEDCO Chief Engineer; Superintending Engineer Tirunelveli Electricity Distribution Circle; Executive Engineer Tamil Nadu Electricity Board; Junior Engineer Devarkulam; 12(3) settlement; certified copy delay 18.04.2026; filed nearly two years later; dismissed as time-barred; decision date 24-06-2026.

What did the court decide?

Section 20 of the Contempt of Courts Act, 1971 prescribes a limitation of one year for initiating contempt proceedings. ¶30

M.Krishnan Vs M.Ambiga, B.E. — Contempt of Court | Madras HC (2026)

What the court decided

AI extract

Outcome

Dismissed

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Issue for consideration

Whether the contempt petition, filed nearly two years after the alleged disobedience, is maintainable in view of the one-year limitation prescribed by Section 20 of the Contempt of Courts Act, 1971. +1 more

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Court's answer

Section 20 of the Contempt of Courts Act, 1971 prescribes a limitation of one year for initiating contempt proceedings.

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Ratio / Principle

Having regard to the law declared by the Hon'ble Apex Court in S.Tirupathi Rao v. M.Lingamaiah, Section 20 of the Contempt of Courts Act being a specific provision, a contempt petition has to be filed within one year when the cause of action arises.

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Key takeaways

In the present case, the cause of action for the petitioner to initiate action for contempt arose on expiry of three months from the date of receipt of a copy of the order dated 16.02.2024.ratio¶36
The petitioner did not take steps within the time prescribed under the Contempt of Courts Act, remained silent for a considerable length of time, and filed the present contempt case nearly two years later.ratio¶37
The present contempt petition, having been filed beyond the limitation prescribed under the Act, is not maintainable.

Detailed headnote1 paragraphs

High Court of Judicature at Madras (T. Vinod Kumar, J.), 24-06-2026 — CONT P No. 2038 of 2026 dismissed. Contempt petition under Section 11 of the Contempt of Court Act, 1971 by M.Krishnan against TANGEDCO/TNEB officials alleging wilful disobedience of the order dated 16.02.2024 in W.P.No.26753 of 2021, which had directed the respondents to consider his representation in the light of earlier judicial proceedings and the 12(3) settlement. The Court noted that Section 20 of the Contempt of Courts Act, 1971 prescribes a one-year limitation for initiating contempt proceedings, and relying on the Hon'ble Apex Court's decision in S.Tirupathi Rao v. M.Lingamaiah (2024 SCC online 1764) and on its own earlier orders dated 28.11.2025 in Cont.P.Nos.2599 and 3033 of 2025 and 12.09.2025 in Cont.P.No.2706 of 2025, held that the cause of action arose on expiry of three months from the date of receipt of a copy of the writ order. The petitioner, however, applied for the certified copy only on 18.04.2026 and filed the contempt petition nearly two years later, remaining silent in the interim. The petition was accordingly held not maintainable as filed beyond the prescribed limitation and was dismissed.

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CONT P No. 2038 of 2026

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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DATED: 24-06-2026

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CORAM

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THE HON'BLE MR.JUSTICE T. VINOD KUMAR

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CONT P No. 2038 of 2026

M.Krishnan

..Petitioner(s)

M.Ambiga, B.E., The Chief Engineer TANGEDCO, Estt., No.144, Anna Salai, Chennai 600 002.

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R.Agilandaeswari, B,E., The Superintending Engineer Tirunelveli Electricity Distribution Circle , Tirunelveli.

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G.Kuthalingam, M.I.E Executive Engineer Tamil Nadu Electricity Board, Tirunelveli -11.

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Selvam

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Junior Engineer Tamil Nadu Electricity Distribution, Devarkulam, Tirunelveli District. .. Respondents

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Prayer: Petition filed under Section 11 of Contempt of Court Act, 1971, praying to punish the respondents for having committed contempt by wilful disobedience of the order of this Court made in Writ Petition No.26753 of 2021 dated 16.02.2024.

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For Petitioner(s) : Mr.V.Elangovan For Respondents : Mr.Venkatesh Prasad.A.P for M/s.Advit Law Chamber

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Page1 of 6

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https://www.mhc.tn.gov.in/judis

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CONT P No. 2038 of 2026

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ORDER

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This contempt petition is filed for not complying with the order dated 16.02.2024 in W.P.No. 26753 of 2021.

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The order copy was uploaded on the High Court website/portal thereafter. The petitioner, applied for certified copy of the order on 18.04.2026 nearly after two years and the same was made ready on 29.04.2026 and delivered on the same day.

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Though on behalf of the petitioner, it is contended that despite this Court directing the respondents to consider the representation of the petitioner in the light of the earlier judicial proceedings and also in the context of 12(3) settlement and pass appropriate orders within a period of four weeks from the date of receipt of a copy of this order, the respondents did not comply with the order and have wilfully disobeyed the order.

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The learned counsel for the petitioner submitted that despite the petitioner following up the matter with the respondents, the respondents kept the issue pending and as such, the petitioner was constrained to file the present contempt case on 18.04.2026.

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https://www.mhc.tn.gov.in/judis

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CONT P No. 2038 of 2026

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I have taken note of the aforesaid submission made on behalf of the

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petitioner.

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At the outset, it is to be noted that Section 20 of the Contempt of Courts Act, 1971 prescribes the limitation of one year for initiating contempt proceedings.

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This Court by order dated 28.11.2025 in Cont.P.Nos.2599 and 3033 of 2025 and by order dated 12.09.2025 in Cont.P.No.2706 of 2025 had considered the scope of Section 20 of the Contempt of Courts Act, 1971 (for short ‘Act 1971’) and Article 215 of the Constitution of India, and also as to what would constitute continuing cause of action.

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This Court having regard to the law declared by the Hon’ble Apex Court in the case of S.Tirupathi Rao V. M.Lingamaiah and others – 2024 SCC online 1764, has held that Section 20 of the Contempt of Courts Act, being a specific provision, the contempt petition has to be filed within one year when the cause of action arises.

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https://www.mhc.tn.gov.in/judis

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CONT P No. 2038 of 2026

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In the facts of the present case, the cause of action for the petitioner to initiate action for contempt had arisen on expiry of three months time granted by this Court from the date of receipt of a copy of the order dated 16.02.2024.

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The petitioner not only did not take steps thereafter within time prescribed under the Contempt of Courts Act, but remained silent for a considerable length of time and approached this Court by filing the present contempt case nearly 2 years later.

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Having regard to the decision of the Hon’ble Apex Court and this

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Court, is of the view that the present contempt petition as filed is not maintainable having been filed beyond the limitations prescribed under the Act.

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