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High Court’s Contempt Proceedings Stayed Pending Review in Satyendra Singh Case

The case of Satyendra Singh vs. Saroj Rani and Others was heard in the Supreme Court of India, under Civil Appellate Jurisdiction, as Civil Appeal No. 1643 of 2012 (arising out of SLP (C) No. 4522 of 2016). The primary concern before the Supreme Court was the continuation of contempt proceedings by the High Court, despite a pending review application filed by the appellant.

Arguments by the Petitioner (Appellant – Satyendra Singh):

  • The appellant had filed a review application before the High Court in Writ Petition No. 2889 (M/B) of 1992.
  • Despite the review application being pending, the High Court was proceeding with contempt proceedings against the appellant.
  • The appellant sought relief from the Supreme Court to ensure that the review application is decided before any contempt proceedings take place.

Arguments by the Respondents (Saroj Rani and Others):

  • The respondents, represented by their learned counsel, argued that the contempt proceedings were justified.
  • They contended that the review application should not hinder the contempt proceedings from proceeding.
  • However, the Supreme Court, after considering their submissions, determined that in the interest of justice, the review application should be decided first.

Supreme Court’s Judgment:

  • The Supreme Court granted leave in the case.
  • The Court ruled that the High Court should dispose of the review application (No. 82/2009) in Writ Petition No. 2889 (M/B) of 1992 within one month from the date of the judgment.
  • The Court also directed the High Court to defer contempt proceedings against the appellant until the review application is resolved.
  • The Supreme Court clarified that the pendency of the review application or contempt proceedings should not prevent the parties from attempting a settlement of their disputes.
  • Additionally, the Court did not express any opinion on the merits of the case, allowing all available contentions to be raised before the High Court.
  • The appeal was disposed of without any order as to costs.

The judgment was delivered by a bench consisting of Justice Kurian Joseph and Justice Rohinton Fali Nariman on February 22, 2016.

This decision ensures that procedural fairness is maintained, preventing unnecessary contempt proceedings while a valid review application remains pending. The judgment also encourages amicable dispute resolution while protecting the legal rights of the appellant.

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