Binding judicial directions cannot be resisted in contempt; Article 32 is unavailable for mining-lease parity relief without a fundamental right breach.

A final judicial direction requiring the State to recommend grant of a mining lease remained binding in contempt proceedings, and the State could not resist compliance by reopening the merits, relying on later developments, or invoking subsequent case-law. Non-compliance was therefore treated as contempt in relation to the Keora area, with a final opportunity given to purge the contempt by making the required recommendation. Separate writ petitions under Article 32 seeking parity relief were not maintainable because non-grant of a mining lease does not itself infringe a fundamental right; the petitioners were left to pursue remedies before the High Court or another appropriate forum.

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Issues: (i) Whether the State could avoid compliance with a final judgment directing recommendation for grant of mining lease by relying on subsequent developments and later case-law. (ii) Whether writ petitions under Article 32 seeking similar relief on the basis of parity were maintainable.

Issue (i): Whether the State could avoid compliance with a final judgment directing recommendation for grant of mining lease by relying on subsequent developments and later case-law.

Analysis: The earlier judgment had finally determined the parties' rights under the memorandum of understanding and directed the State to make the requisite recommendation. In contempt proceedings, the correctness of that judgment could not be reopened, nor could the State traverse beyond the operative directions by invoking overlapping applications, later legal developments, or the decision in Sandur Manganese. A party bound by a final order must obey it and, if aggrieved, pursue the proper remedial route rather than resist implementation in contempt.

Conclusion: The State's resistance to implementation was rejected and contempt was held to be made out in respect of non-compliance concerning the Keora area, with a final opportunity granted to purge the contempt by making the required recommendation.

Issue (ii): Whether writ petitions under Article 32 seeking similar relief on the basis of parity were maintainable.

Analysis: The petitioners sought extension of the benefit granted in the earlier judgment, but no fundamental right is violated by non-grant of a mining lease. The Court therefore held that Article 32 could not be directly invoked to secure such relief. The petitioners were left free to approach the High Court or any other appropriate forum, where their entitlement could be examined on merits.

Conclusion: The writ petitions were held to be not maintainable under Article 32 and were dismissed with liberty to pursue other remedies.

Final Conclusion: The earlier directions were treated as binding and enforceable against the State, while the independent writ petitions for parity were rejected at the threshold with liberty to seek relief before the appropriate forum.

Ratio Decidendi: A final and binding judicial direction cannot be resisted in contempt proceedings by reopening merits or invoking later developments, and Article 32 cannot be used to claim mining-lease relief where no fundamental right is infringed.

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