Summary and Analysis of A K Jayaprakash Dead through LRs vs S S Mallikarjuna Rao & Anr
1. Heading of the Judgment
Case Name: A.K. Jayaprakash (Dead) through LRs vs S.S. Mallikarjuna Rao & Another
Citation: 2025 INSC 1003 (Non-Reportable)
Court: Supreme Court of India
Jurisdiction: Contempt of Court
Judges: Hon'ble Mr. Justice B.R. Gavai and Hon'ble Mr. Justice Augustine George Masih
Date of Judgment: August 19, 2025
2. Related Laws and Sections
This judgment deals with the law of contempt of court, specifically:
The Contempt of Courts Act, 1971: This Act defines and punishes civil and criminal contempt. Civil contempt is the willful disobedience of any judgment, order, or direction of a court.
The core legal principle is that for an act to amount to civil contempt, it must be a willful, deliberate, and intentional disobedience of a court order. Mere delay or negligence, without a contumacious (stubbornly disobedient) intent, may not be sufficient to punish someone for contempt.
3. Basic Judgment Details
Petitioner: The late A.K. Jayaprakash, a former bank manager, and after his death, his legal heirs (his widow and others).
Respondents (Alleged Contemnors): S.S. Mallikarjuna Rao and another, officials of Punjab National Bank (which had merged with the original employer, Nedungadi Bank Ltd.).
Origin: The petitioner was dismissed from service in 1985. After a long legal battle, the Supreme Court, on January 17, 2018, dismissed the bank's appeal and directed it to pay the "outstanding amount" to the petitioner within three months.
The Contempt Petition: The bank did not pay the money within the stipulated three months. The payments were made in 2019, after a significant delay. The petitioner filed this contempt petition alleging willful disobedience of the Supreme Court's order. The petitioner also raised a new claim for pensionary benefits.
Final Outcome: The Supreme Court disposed of the contempt petition. It held the bank officials were not guilty of willful contempt but ordered the bank to pay the petitioner's family an additional ₹3 lakhs as compensation for the prolonged delay and hardship.
4. Explanation of the Judgment
The Supreme Court's decision revolved around two main questions.
1. Was the bank's delay in payment willful contempt?
The bank admitted it missed the three-month deadline set by the Court. Payments for back wages, gratuity, and provident fund were made between March and June 2019, which was over a year after the deadline.
The Court's Reasoning:
The Court acknowledged the delay was a fact. However, it referred to precedents like Ashok Paper Kamgar Union and Rama Narang, which state that for an act to be civil contempt, it must be deliberate and intentional.
The bank provided an explanation: the delay was due to administrative difficulties caused by the merger of Nedungadi Bank with Punjab National Bank and the challenge of retrieving records that were over three decades old.
The Court concluded that while this explanation did not justify the laxity, the material on record did not prove that the delay was due to a willful or contumacious intent (known as mens rea or a "guilty mind").
Therefore, the essential ingredient for finding contempt was missing. The bank officials were discharged from the contempt charges.
2. Can the claim for pension be raised in a contempt petition?
The petitioner argued that besides the delayed payments, the bank had also not paid him pensionary benefits, which he claimed he was entitled to.
The Court's Reasoning:
The Court firmly rejected this argument. It clarified the fundamental purpose of contempt jurisdiction:
Contempt proceedings are not a forum to raise new claims or seek new reliefs. Their sole purpose is to punish the disobedience of an existing, clear order of the court.
The original Supreme Court order dated January 17, 2018, only directed the payment of the "outstanding amount" as determined by the lower courts. This did not include any mention of pension, as this claim had never been adjudicated upon in the entire long history of the case.
To claim pension, the petitioner would have had to raise it in the original proceedings or file a separate case. He could not use contempt proceedings to "circumvent proper adjudication mechanisms."
Conclusion: Balancing Technicality with Equity
Although the Court found no willful contempt, it was acutely aware of the immense hardship suffered by the petitioner.
He was dismissed in 1985.
He got a favourable order from the labour authorities in 2004.
He superannuated in 2006 but received no retirement benefits.
The Supreme Court's final order came in 2018, but the payments were still delayed until 2019.
The petitioner passed away during the pendency of this contempt petition.
Recognizing this "protracted delay" and to prevent future litigation and bring a "quietus" (a final end) to the matter, the Court used its inherent power to do complete justice. It directed the bank to pay a lump sum compensation of ₹3,00,000 (Three Lakhs) to the petitioner's widow. This was not a punishment for contempt but an equitable compensation for the bank's laxity and the immense hardship endured by the employee and his family for over four decades.
In summary, the Court distinguished between a willful disobedience (which is punishable as contempt) and administrative delay and negligence (which, while wrong, may not attract contempt charges). It also reaffirmed that contempt power cannot be used to get new reliefs. However, by awarding compensation, it ensured that justice was not just a technical legal victory but also addressed the human cost of delayed justice.