Binding judicial declarations must be followed by quasi-judicial authorities; ignoring them can amount to wilful disobedience and contempt.

A quasi-judicial authority must give effect to a final High Court declaration between the same parties and cannot proceed on a contrary basis once that declaration is brought to its notice. The earlier writ order had held that deletion of the word "Private" from the company's name occurred by operation of law under the Companies Act and not by any voluntary act. The appellate order nevertheless assumed a need for prior permission and liability to pay unearned profit without findings of assignment, under-letting, or transfer. This was treated as wilful disobedience and contempt, although the unconditional apology was accepted, costs were imposed, and the matter was closed.

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Issues: Whether the respondent's order passed in appeal amounted to wilful disobedience of the High Court's earlier order declaring that the change in the petitioner company's name occurred by operation of law and not by any voluntary act of the company.

Analysis: The prior writ order had conclusively held that the deletion of the word "Private" from the company's name was the result of operation of law under section 43A(1A) of the Companies Act, 1956, and not a voluntary change. That declaration had attained finality and bound the authorities before whom the appeal was pending. The respondent, while deciding the appeal, nonetheless proceeded on the basis that prior permission of the Collector was required and that the petitioner was liable to pay unearned profit, without recording any finding of assignment, under-letting, or transfer that would attract the lease clause. A quasi-judicial authority cannot ignore a binding judicial declaration brought to its notice and decide contrary to it.

Conclusion: The respondent's order was in contravention of the earlier High Court order and amounted to wilful disobedience, constituting contempt of court.

Final Conclusion: The contempt was found, but the unconditional apology was accepted, costs were imposed, and the matter was closed.

Ratio Decidendi: A quasi-judicial authority is bound by a final declaration of law or fact made by the High Court in proceedings between the same parties and commits contempt if it knowingly decides contrary to that binding declaration without any supporting factual finding.

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