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Supreme Court of India 2021-10-26 allowed

U.N. Bora, Ex. Chief Executive Officer & Ors vs Assam Roller Flour Mills Association & Anr

Bench: 2 — M.M. Sundresh

In Brief

The Supreme Court set aside a High Court order that found agricultural marketing board officials guilty of contempt for allegedly violating directions on cess levy under the Assam Agricultural Produce Market Act, 1972. The Court held that contempt requires proof of willful, deliberate disobedience beyond reasonable doubt. Vicarious liability cannot apply in contempt proceedings merely because subordinates acted without proof of knowledge or collusion by higher officials. The High Court erred by examining disputed factual evidence and making findings that it had earlier declined to consider. Since the original judgment provided an alternative committee mechanism for resolving disputes, parties should exhaust that remedy before seeking contempt relief. The appeal was allowed and the contempt conviction was set aside.

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Contempt of Courts Civil Procedure Administrative Law Agricultural Marketing Constitutional Law

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