Written consent for contempt proceedings remained mandatory, and refusal of consent was not shown to be unlawful.

Revival of a contempt petition was contingent on compliance with Section 15 of the Contempt of Courts Act, 1971 and Rule 3(c), requiring written consent or a legally unsustainable refusal of consent. The Court treated the earlier liberty to revive as conditional on meeting that statutory prerequisite and examined whether the Solicitor General's refusal was irrelevant, arbitrary, illegal, or unreasonable. On the reasons supplied, the refusal was not shown to be unlawful, so the conditions precedent for maintainability were not satisfied and the revival application failed.

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Issues: Whether the petitioner could revive the contempt petition without satisfying the requirement of written consent under Section 15 of the Contempt of Courts Act, 1971 and Rule 3(c), and whether the Solicitor General's refusal of consent was shown to be irrelevant or unlawful.

Analysis: The prayer for revival was examined against the earlier orders of the Court, which had made clear that the contempt petition would lie only if the statutory requirement of consent was met. The Court noted that the petitioner had proceeded on the same footing and that the earlier liberty to revive was expressly linked to obtaining the requisite consent. It further held that the petitioner could succeed only by showing either written consent of the Solicitor General or that the refusal was on an irrelevant ground. On scrutiny of the reasons supplied by the Solicitor General, the Court found that the refusal could not be described as irrelevant, arbitrary, illegal, or unreasonable.

Conclusion: The petitioner was not entitled to revive the contempt petition, as the conditions precedent for maintainability were not satisfied. The applications were dismissed.

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