Supreme Court Holds That Contempt Jurisdiction Can Be Used to Secure Complete Compliance of Its Directions and Orders Refund of Non-Judicial Stamp Value Despite Statutory Limitation Rules

ase Name: Dharmendra Sharma v. M. Arunmozhi & Anr.
Citation: 2026 INSC 10
Date of Judgment/Order: 05 January 2026
Bench: Justice Vikram Nath and Justice Sandeep Mehta

Held: The Supreme Court held that when its earlier judgment had expressly directed return of the value of non-judicial stamp papers, any subsequent refusal by State authorities to refund the amount on the basis of statutory limitation rules amounts to non-compliance, and the Court is empowered in contempt jurisdiction to issue directions to secure complete and meaningful enforcement of its orders.

Summary: The contempt petitions arose from alleged non-compliance with the Supreme Court’s judgment dated 06.09.2024 in Dharmendra Sharma v. Agra Development Authority, wherein the Court had directed refund of the entire deposited amount with interest, additional compensation, and return of non-judicial stamp papers worth Rs. 3,99,100. While the Agra Development Authority complied with the monetary directions, it merely returned the physical stamp papers after their expiry. The petitioner’s request for refund of stamp value was rejected by the State registration authorities on the ground that refund was barred under Rule 218 of the U.P. Stamp Rules due to lapse of time. After impleadment of the State of Uttar Pradesh, the Supreme Court noted the unconditional apology tendered by the State and its obligation to implement the Court’s directions, and examined the matter strictly from the standpoint of compliance with its earlier judgment.

Decision: The contempt petitions were disposed of with a direction to the State of Uttar Pradesh to refund a sum of Rs. 3,99,100 to the petitioner within two months upon return of the non-judicial stamp papers, the contempt proceedings against the development authority were closed, and all pending applications stood disposed of.