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Supreme Court of India 2021-10-26 allowed

DR. U.N. BORA, EX. CHIEF EXECUTIVE OFFICER & ORS vs ASSAM ROLLER FLOUR MILLS ASSOCIATION & ANR

Bench: 2 — Sanjay Kishan Kaul, M.M. Sundresh

In Brief

The Supreme Court set aside the High Court's contempt conviction of agricultural board officials for allegedly violating a court order regarding cess levy under the Assam Agricultural Produce Market Act. The Court held that civil contempt requires proof of willful disobedience beyond reasonable doubt, with a culpable mental element. Vicarious liability is inapplicable in contempt—superiors cannot be liable for subordinates' acts without knowledge or complicity. The High Court erred by examining disputed factual questions in contempt proceedings when it had directed parties to an alternative committee remedy. The Court ruled that contempt jurisdiction cannot be used when other remedies exist, and set aside the conviction.

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Contempt of Court Civil Contempt Administrative Law Willful Disobedience Agricultural Marketing Constitutional Law

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