Coordinate Bench contempt finding cannot be reopened by a later Single Judge; the prior order must be carried forward.

A Single Judge in contempt proceedings cannot reopen or negate a prior contempt finding recorded by a coordinate Bench; once wilful disobedience has already been held, the later Bench must proceed only from that stage and cannot discharge the notice by reassessing whether contempt existed. The proper remedy against the earlier finding is a statutory appeal, not a fresh merits review by another Single Judge. The Supreme Court held that the later order was beyond jurisdiction and inconsistent with judicial propriety, set it aside, and remitted the matter to proceed from the stage after the earlier contempt order.

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Issues: Whether a later Single Judge of the same Court could revisit a prior contempt finding recorded by another Single Judge and discharge the show-cause notice instead of proceeding from the stage at which contempt had already been found.

Analysis: A prior order of the coordinate Bench had unequivocally held the respondent guilty of intentional and mala fide disobedience and had only granted time to purge the contempt or explain why punishment should not follow. In such a situation, the later Bench could not reopen the question whether contempt had been committed, because that would amount to sitting in appeal over a coordinate Bench order. The proper course, if the earlier contempt finding was challenged, was to pursue the statutory appeal. By re-examining the merits and concluding that no wilful disobedience existed, the later Bench acted beyond its jurisdiction and contrary to settled judicial propriety.

Conclusion: The later order discharging the notice was unsustainable and liable to be set aside. The matter had to be remitted to the High Court to proceed from the stage after the earlier contempt finding.

Final Conclusion: The appeal succeeded, and the impugned judgment was quashed with the matter sent back for consideration from the stage following the earlier contempt order.

Ratio Decidendi: A Single Judge cannot, in contempt proceedings, reopen or negate a contempt finding already recorded by a coordinate Bench; the later Bench must proceed only within the limited consequences flowing from that earlier order, subject to the statutory appellate remedy.

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