Safiya Malik

The High Court of Punjab and Haryana Single Bench of Justice Sudeepti Sharma dismissed a contempt petition alleging non-compliance with its earlier directions on registering FIRs where cognizable offences are disclosed and ensuring due implementation of the PCPNDT framework, finding no willful disobedience by the official respondents. At the outset, the Court cautioned the petitioner, appearing in person, that costs of ₹1,00,000 would follow if the plea was found frivolous; the petitioner responded by seeking costs of ₹2,00,000 instead in that event. Holding the petition to be a frivolous, vexatious filing and a gross abuse of process, the Court imposed exemplary costs of ₹3,00,000, payable to the respondent officials in equal shares, with recovery in default.

The petitioner, appearing in person, filed a contempt petition alleging deliberate and intentional disobedience of an earlier High Court order dated 30 July 2024, which had directed the State to register an FIR when a complaint disclosed a cognizable offence (as per Lalita Kumari) and to follow the Pre-Conception and Pre-Natal Diagnostic Techniques Act, 1994.

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In the petition, the petitioner sought initiation of contempt proceedings against senior police officials and also asked for directions to register an FIR against certain police officers and for investigation by the CBI or an independent agency, citing allegations including embezzlement of government funds, forgery/tampering of records, and manipulation of investigation and challan.

The respondents filed an affidavit dated 20 January 2026 by the Director General of Police, stating that the matter related to District Faridkot and that a report and documents were obtained from the Senior Superintendent of Police, Faridkot. The affidavit referred to a prior complaint dated 5 April 2024, registration of an FIR dated 4 February 2025 under IPC sections including 409, 420, 465, 468 and 471 (with 467/120-B later), and investigation by a Special Investigation Team, including its report dated 13 October 2025 and presentation of challan on 15 October 2025.

The Court recorded at the outset: “At the very outset, this Court apprised the petitioner, who is present in-person, that in the event the present contempt petition is found to be frivolous, costs of Rs.1,00,000/- would be imposed.” It further noted the petitioner’s response that he insisted higher costs be imposed if the petition was found frivolous.

After examining the compliance affidavit, the Court observed: “A perusal of the compliance affidavit as well as the material placed on record reveals that the directions issued by the Division Bench have been duly complied with. No material has been produced by the petitioner to establish any willful, deliberate or disobedience on the part of the respondents.”

The Court stated: “Further from the compliance affidavit, it is clear that the petitioner is in the habit of filing frivolous contempt petitions.” It added, “The present case is the set example of the litigants, who are in the habit of blaming/targeting the official respondents unnecessarily.”

On the scope of contempt jurisdiction, the Court recorded: “It is well settled that contempt jurisdiction is required to be exercised with great caution and circumspection and only in cases where willful and intentional disobedience of an order of the Court is clearly made out.” It further observed, “The jurisdiction cannot be invoked to settle scores or to unnecessarily harass officials, particularly when the record reflects compliance with the directions issued by this Court.”

Referring to precedents, the Court quoted the Supreme Court in Dalip Singh: “a litigant who attempts to pollute the stream of justice or touches the pure fountain of justice with tainted hands is not entitled to any relief, interim or final.”

The Court concluded: “In view of the above referred to judgments, this Court is firmly of the opinion that the instant petition constitutes a glaring instance of misuse of the judicial process.” It also recorded: "the time has come when not only deterrent costs must be imposed upon the official respondents but also upon the frivolous litigants. If, in cases of genuine disobedience, costs can be imposed upon officials and recovered from their salaries, there is no reason why, in cases of manifest abuse of process such as the present one, the erring petitioner should not be saddled with exemplary costs payable to the affected officials."

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The Court ordered: “Accordingly, with a view to sending a strong deterrent message and to preserve the sanctity of judicial proceedings, this Court deems it appropriate to impose costs of Rs.3,00,000/- upon the petitioner. The said amount shall be deposited with the Department of Home, Punjab, which shall disburse the same to the respondents in the present contempt petition in equal shares in their respective accounts.”

“Consequently, the present contempt petition is dismissed with costs of Rs.3,00,000/- (Rupees Three Lakh only), payable to the respondents in equal shares, i.e. Rs.1,00,000/- each, to be credited into their respective accounts. In the event of default in compliance, the amount shall be recovered from the petitioner as arrears of land revenue by the competent authority.”

Advocates Representing the Parties

For the Petitioners: Mr. Rajbir Singh Brar, petitioner in-person

For the Respondents: Mr. Ravneet S. Joshi, DAG, Punjab

Case Title: Rajbir Singh Brar v. Gaurav Yadav and others

Neutral Citation: 2026: PHHC:019328

Case Number: COCP-5983-2025 (O&M)

Bench: Justice Sudeepti Sharma