Binding High Court precedent must be followed by subordinate authorities; deliberate non-compliance can amount to civil contempt.

Authorities and tribunals subject to High Court superintendence must follow the law declared by the High Court, and deliberate disregard of that binding position after it is specifically brought to notice may amount to civil contempt. Encashment of a bank guarantee during the appeal period was treated as a coercive step contrary to the settled legal position, reflecting wilful non-compliance with binding precedent. The contempt proceedings were ultimately closed after the unconditional apology and assurance of future compliance were accepted, but the Court reaffirmed that subordinate authorities cannot disregard High Court law.

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Issues: Whether an authority subordinate to the High Court can disregard binding law declared by the High Court and encash a bank guarantee during the appeal period, and whether such conduct amounts to civil contempt.

Analysis: The legal position is that authorities and tribunals subject to the High Court's superintendence must follow the law declared by the High Court. Deliberate disregard of that law, especially after the position has been specifically brought to the officer's notice, undermines the authority of the Court and falls within the concept of civil contempt. Encashment of a bank guarantee before expiry of the appeal period was treated as a coercive measure contrary to the settled legal position.

Conclusion: The conduct was held to constitute wilful disregard of binding precedent and to attract civil contempt, but the show cause notice was discharged in view of the unconditional apology and the assurance of future compliance.

Final Conclusion: The Court reaffirmed that subordinate authorities must obey the law declared by the High Court, while ending the contempt proceedings after accepting the apology and assurance.

Ratio Decidendi: Law declared by a High Court binds authorities and tribunals under its superintendence, and deliberate non-compliance with that law may amount to civil contempt.

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