Supreme Court: Tenants Held Guilty of Contempt for Defying Eviction Orders, One Fined ₹5 Lakh and Another Sentenced to Three Months Civil Imprisonment

Case Name: M/s Laxmi Construction & Anr. v. Harsh Goyal & Anr.
Date of Judgment: September 26, 2025
Citation: Contempt Petition (Civil) No. 218 of 2025 in SLP (C) No. 21177 of 2024
Bench: Hon’ble Mr. Justice J.K. Maheshwari and Hon’ble Mr. Justice Vijay Bishnoi

Held: The Supreme Court held the respondents-tenants guilty of willful and deliberate contempt under Section 2(b) of the Contempt of Courts Act, 1971 for not complying with eviction orders and undertakings to vacate the premises. Despite being granted time until 31.03.2025 and furnishing undertakings, the tenants failed to hand over possession, instead filing recall applications and further petitions to delay execution. The Court imposed a fine of ₹5,00,000 on one contemnor (aged 82) in lieu of imprisonment, while sentencing the other to three months’ civil imprisonment along with a fine of ₹1,00,000.

Summary: The case arose from eviction proceedings initiated by M/s Laxmi Construction, upheld successively by the Rent Controlling Authority (07.09.2022), Rent Appellate Authority (22.01.2024), the Allahabad High Court (14.05.2024), and finally the Supreme Court (20.09.2024) in SLP (C) No. 21177 of 2024. The tenants, Harsh Goyal and Rajesh Goyal, were given until 31.03.2025 to vacate upon furnishing undertakings. Instead, they filed a recall application, which was improperly allowed ex parte by the Rent Controlling Authority but later set aside by the High Court. Further SLPs were dismissed with costs of ₹5 lakh, with even the Rent Authority being issued a contempt notice for entertaining the recall. Despite repeated opportunities, the tenants neither vacated nor complied, while attempting to mislead the Court about their financial capacity. The Court found their conduct a grave abuse of process and overreach of judicial orders.

Decision: The Supreme Court imposed a fine of ₹5 lakh on Contemnor No. 1 (aged 82), failing which he must undergo one month’s civil imprisonment. Contemnor No. 2 was directed to serve three months’ civil imprisonment and pay a fine of ₹1 lakh, failing which an additional one month’s imprisonment would follow. He was taken into custody in Court and handed to Tihar Jail authorities. The District Judge, Saharanpur, was directed to take possession of the property with police assistance and submit a compliance report. The contempt petition was accordingly disposed of.