Binding High Court precedent must be followed by quasi-judicial authorities; deliberate refusal can amount to contempt of court.

A quasi-judicial authority that knowingly and mala fide refuses to follow a binding High Court decision, while exercising powers under a State enactment, acts contrary to judicial discipline and the rule of law. A High Court's decisions bind courts and tribunals within its supervisory jurisdiction, and a deliberate departure supported by factually wrong or illegitimate reasons is not a bona fide distinction of precedent but contemptuous conduct. The presence of a quasi-judicial proceeding does not protect such disobedience. The appellant's conduct was treated as contemptuous, and the appeal failed.

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Issues: Whether a quasi-judicial authority commits contempt by deliberately and mala fide refusing to follow a binding decision of the High Court while exercising powers under a State enactment.

Analysis: A High Court's decisions are binding on courts and tribunals subject to its superintendence under Article 227 of the Constitution of India. Where such an authority knowingly disregards that law and offers factually wrong or illegitimate reasons for doing so, the conduct is not a bona fide attempt to distinguish precedent but a deliberate departure from binding authority. Such conduct tends to create confusion in the administration of law, undermines respect for the High Court's constitutional authority, and falls within the principles underlying contempt of court. The fact that the act occurs in a quasi-judicial proceeding does not protect a deliberate and mala fide refusal to follow binding precedent.

Conclusion: The appellant's conduct was held to be contemptuous, and the appeal failed.

Ratio Decidendi: A deliberate and mala fide refusal by a subordinate court or quasi-judicial authority to follow a binding decision of the High Court is contempt of court, because obedience to the law declared by the High Court is integral to judicial superintendence, the administration of justice, and the rule of law.

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