Delhi High Court Upholds Constitutional Validity of Section 20, Contempt of Courts Act: Writ Petition Dismissed for Lack of Legal Substance 

Introduction 

In the matter of Rajesh Ranjan v. Union of India & Ors. [W.P.(C) 4965/2025], the Delhi High Court (‘the Court’) was called upon to adjudicate a constitutional challenge against s. 20 of the Contempt of Courts Act, 1971. The petitioner, invoking a. 226 of the Constitution, sought a writ of mandamus and various declaratory reliefs, praying for s. 20 to be struck down as being violative of a. 13, 14, and 20 of the Constitution. The petitioner’s grievances were rooted in his dissatisfaction with the implementation of a Tribunal order, which had a consequential effect on his service seniority. The Court, however, firmly rejected the challenge, holding that the petition lacked both legal merit and constitutional foundation. 

Brief Facts  

Rajesh Ranjan, an Under Secretary in the Ministry of External Affairs, had previously been arrayed as a respondent in OA No. 1719/2012 before the Central Administrative Tribunal (‘CAT’), Principal Bench. The Tribunal, vide order dated 29.02.2020, directed the re-fixation of seniority of officers promoted through Limited Departmental Competitive Examination (‘LDCE’), clarifying that such officers were not entitled to retrospective seniority. 

The Tribunal’s order was upheld by the Delhi High Court in W.P.(C) 4339/2020, and the subsequent challenge to that judgment was dismissed by the Supreme Court in SLP Nos. 23008–09/2024. When the Tribunal’s order was not implemented within the stipulated time, the original applicants-initiated contempt proceedings (CP No. 961/2024) under s. 17 of the Administrative Tribunals Act and s. 12 of the Contempt of Courts Act. Notices were issued, and eventually, a draft consolidated seniority list was published by the government on 24.02.2025. 

The petitioner, aggrieved by the said seniority list and contending that the contempt petition was barred by limitation under s. 20, filed the present writ petition challenging the constitutional validity of s. 20 itself. He argued that the provision violated his fundamental rights and relied on the Supreme Court’s decision in S. Tirupathi Rao v. M. Lingamaiah to contend that s. 20 had become redundant. 

Held 

The Court, after hearing the matter, dismissed the petition in limina. The Bench held that the writ petition was wholly devoid of substance and did not raise any legally sustainable grounds to challenge the vires of s. 20. 

The Court emphasized that a challenge to the constitutional validity of a statute must satisfy specific parameters laid down by the Supreme Court, particularly those concerning permissible classification, arbitrariness, or excessive delegation. It reiterated the legal position that there is always a strong presumption in favour of the constitutionality of legislation, and the burden lies on the petitioner to establish its invalidity. 

The Court observed that the petition was, in essence, a manifestation of the petitioner’s personal grievance against the seniority list issued in compliance with the Tribunal’s order. The petitioner’s principal objection appeared to be the Tribunal’s entertainment of the contempt petition despite the alleged limitation bar. However, this did not constitute a constitutional infirmity in s. 20. The Court further noted that the petitioner had not participated in the contempt proceedings, but such inability did not furnish grounds to invalidate a statutory provision. 

The Bench held that none of the arguments advanced satisfied the well-settled constitutional parameters under a. 14 or 20. There was no demonstrable arbitrariness, discrimination, or procedural unfairness inherent in s. 20. The oral submissions of the petitioner’s counsel also failed to articulate any rational basis to even warrant the issuance of notice. Consequently, the writ petition was dismissed at the threshold, without costs. 

Our Analysis 

The Court judgment in this matter is a reaffirmation of the constitutional discipline required for successfully assailing a statutory provision. S. 20 of the Contempt of Courts Act prescribes a one-year limitation period for initiating contempt proceedings. The petitioner’s argument that this provision was unconstitutional was largely rooted in a personal grievance namely, that he was adversely affected by a seniority list issued pursuant to contempt proceedings he claims were time-barred. 

The Court correctly identified that the petitioner’s contentions failed to rise above personal dissatisfaction. The presumption of constitutionality, coupled with the burden of establishing an unmistakable breach of fundamental rights, was not discharged. The petition was not only bereft of legal substance but also illustrative of an increasing tendency to invoke constitutional writ jurisdiction for collateral purposes. 

It is also significant that the petitioner attempted to rely on S. Tirupathi Rao, a judgment that clarified the interpretation of limitation in contempt matters, but did not render s. 20 ineffective or ultra vires. This misreading further weakened the petition. 

In merging the constitutional challenge with personal service-related disputes, the petitioner blurred the lines between judicial review of legislation and review of administrative action. The High Court’s refusal to entertain the petition underscores that a. 226 cannot be used as a tool to second-guess settled judicial determinations through backdoor challenges to legislation. 

The ruling in Rajesh Ranjan v. Union of India serves as a vital judicial reminder that constitutional challenges must be rooted in serious legal infirmities and not cloaked in personal grievances. It strengthens the jurisprudential foundation that limitation provisions in statutes like the Contempt of Courts Act are essential components of procedural law and do not, in themselves, infringe fundamental rights. 

By upholding the constitutional validity of s. 20, the Delhi High Court has once again underscored the principle that laws must not be declared invalid lightly, and judicial review must operate within the confines of constitutional reasonableness, not individual dissatisfaction. 

Authored by Ascend Legal Editorial Team. The opinions expressed are personal and do not constitute any legal advocacy.