Collateral writ challenges to Supreme Court orders are impermissible; coercive enforcement, including detention, may secure compliance with monetary directions.

A fresh writ petition cannot be used to collaterally attack a final judicial order of the Supreme Court by re-labelling the challenge as habeas corpus, certiorari or mandamus; correction lies through review or curative jurisdiction. The Court's constitutional powers under Articles 129 and 142 may be used to enforce its own orders where no separate execution mechanism exists, and a complaint of natural justice fails where notice, reply and hearing were afforded. Arrest and detention may be employed as coercive enforcement measures for binding monetary directions where the contemnors have means but do not comply. Allegations of bias require a factual basis of reasonable apprehension and mere dissatisfaction is insufficient.

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Issues: (i) Whether the writ petition was maintainable to challenge an order of arrest and detention passed by the Supreme Court in contempt proceedings; (ii) whether the impugned order was without jurisdiction or in violation of natural justice; (iii) whether arrest and detention could be ordered for enforcement of the monetary obligations arising from the Court's earlier directions; (iv) whether bias or recusal was established.

Issue (i): Whether the writ petition was maintainable to challenge an order of arrest and detention passed by the Supreme Court in contempt proceedings.

Analysis: A challenge to a judicial order of the Supreme Court could not be entertained by way of a fresh writ petition merely by invoking ex debito justitiae or by re-labelling the relief as habeas corpus, certiorari, mandamus, or a petition under Articles 129 and 142. The judgment relied on the settled position that judicial orders of a competent court attain finality and are not open to collateral attack in writ jurisdiction. The proper avenues for correction were review and, where permissible, curative jurisdiction.

Conclusion: The writ petition was not maintainable.

Issue (ii): Whether the impugned order was without jurisdiction or in violation of natural justice.

Analysis: The Court held that it had jurisdiction under Articles 129 and 142 to enforce its own orders when the SEBI regime contained no separate execution mechanism. It further found that the petitioner had notice of the applications seeking arrest, had filed a personal affidavit in reply, had been subjected to repeated hearings, had been directed to appear personally, and was heard before the impugned order was passed. The allegation of violation of natural justice was therefore rejected.

Conclusion: The impugned order was neither without jurisdiction nor passed in breach of natural justice.

Issue (iii): Whether arrest and detention could be ordered for enforcement of the monetary obligations arising from the Court's earlier directions.

Analysis: The Court held that arrest and detention are recognised modes of enforcing financial liabilities under the Code of Civil Procedure and the Code of Criminal Procedure. Although those provisions did not directly govern SEBI Act proceedings, the Court found that the underlying parameters reflected in Section 51 of the Code of Civil Procedure, 1908 were satisfied: the contemnors had means to pay, had not paid, had obstructed compliance, and had adopted evasive and dishonest explanations regarding alleged redemptions. The Court also held that the earlier directions regarding repayment retained their binding force.

Conclusion: Arrest and detention were permissible to enforce compliance with the Court's monetary directions.

Issue (iv): Whether bias or recusal was established.

Analysis: The Court found no factual basis for a reasonable apprehension of bias. It held that the request for recusal was unsupported by any direct interest, personal animus, or material showing pre-judgment. The Court also noted that the allegations were advanced in a manner it treated as an attempt to avoid an inconvenient bench rather than a genuine bias complaint.

Conclusion: Bias was not made out and recusal was declined.

Final Conclusion: The challenge to the arrest and detention order failed on maintainability, jurisdiction, natural justice, and bias grounds, and the Court upheld its power to enforce compliance with its earlier monetary directions through contempt-based coercive measures.

Ratio Decidendi: A writ petition cannot be used to collaterally challenge a final judicial order of the Supreme Court, and where a party has notice and opportunity but still fails to comply with binding monetary directions, the Court may, in exercise of its constitutional powers, employ coercive measures including arrest and detention to secure obedience.

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