"Accidental or unintentional disobedience is not sufficient to justify one for holding guilty of contempt," a bench of Justices J M Panchal and Gyan Sudha Mishra held in their judgment.
"It is further relevant to bear in mind the settled law on the law of contempt that casual or accidental or unintentional acts of disobedience under the circumstances which negate any suggestion of contumacy, would amount to a contempt in theory only and does not render the contemnor liable to punishment," the court said.
The court gave the verdict while quashing the contempt proceedings initiated against Dinesh Kumar Gupta, deputy registrar (judicial), Rajasthan high court.
Gupta had moved the apex court questioning the contempt proceedings initiated against him by the single judge of the high court on December 8, 2006 for an alleged contempt committed by his predecessor in 2001 vis-a-vis an order passed by the judge on March 22, 2001.
The high court had initiated contempt against Gupta on the ground that the order for initiating inquiry against a motor accidents claims tribunal judge S K Bansal was sought to be scuttled by the registry.
Upholding the appeal, Justice Sudha, writing the judgment, said at the relevant period of order passed by the high court, Gupta was not the deputy registrar (judicial) as he had assumed office more than four years later.
"Besides this, it would also not be correct to overlook or ignore an important statutory ingredient of contempt of a civil nature given out u/s 2(b)of the Contempt of Courts Act 1971 that the disobedience to the order alleging contempt has to satisfy the test that it is a willful disobedience to the order.
"Bearing this important factor in mind, it is relevant to note that a proceeding for civil contempt would not lie if the order alleged to have been disobeyed itself provides scope for reasonable or rational interpretation of an order or circumstance which is the factual position in the instant matter," the apex court said.
The apex court said the single judge had inferred and assumed erroneously that Gupta had the intention to obstruct the administration of justice by being instrumental in ensuring not implementation of the order.
"It would equally not be correct to infer that a party although acting due to misapprehension of the correct legal position and in good faith without any motive to defeat or defy the order of the court, should be viewed as a serious ground so as to give rise to a contempt proceeding," the bench added.
