Limited appeal under contempt law requires a punishment order; compliance directions alone are not appealable.

Section 19 of the Contempt of Courts Act, 1971 confers a limited appeal only against an order passed in the exercise of jurisdiction to punish for contempt. An order that does not record guilt or impose punishment, but merely directs compliance-related steps such as deposit or release of monies, or appearance on non-compliance, is not an appealable contempt punishment order. Applying that interpretation, the Delhi HC held that the impugned order fell outside Section 19 and the appeal was not maintainable.

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Issues: Whether an appeal under Section 19 of the Contempt of Courts Act, 1971 is maintainable against an order passed in contempt proceedings that does not record a finding of guilt or impose punishment.

Analysis: Section 19 provides a limited right of appeal only against an order or decision passed in the exercise of jurisdiction to punish for contempt. An order that merely directs deposit or release of monies, or requires appearance on the event of non-compliance, is not itself an order imposing punishment. The impugned order did not hold the appellant guilty of contempt and did not award punishment; it only contained consequential directions in aid of compliance. On the settled interpretation of the provision, such an order falls outside the scope of an appeal under Section 19.

Conclusion: The appeal was not maintainable under Section 19 of the Contempt of Courts Act, 1971 and was dismissed.

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