Telangana High Court sentences a Collector to six months and Gujarat makes another pay Rs 1 lakh

The Ranga Reddy Collector got six months, suspended for four weeks. The Ahmedabad Collector must pay Rs 1 lakh from his own salary. Article 215, the Contempt of Courts Act, apology, appeal under section 19 and personal costs explained.

Two High Courts have turned on District Collectors for not obeying their orders. The Telangana High Court has sentenced the Ranga Reddy Collector to six months in prison for contempt, and the Gujarat High Court has ordered the Ahmedabad Collector to pay Rs 1 lakh from his own salary for repeating a decision it had already quashed.

The two orders rest on different powers. One is a conviction for civil contempt under the Contempt of Courts Act, 1971. The other is an order of personal costs in a writ petition, with no finding of contempt reported.

Telangana: six months for ignoring a 60-day direction

Justice K. Lakshman sentenced the Collector to six months of simple imprisonment and a fine of Rs 2,000, and suspended the sentence for four weeks. The order was reported on 9 November 2026, and the reports do not give the date on which it was pronounced.

In August 2025 the writ court had directed the Collector to consider the petitioners' representation within 60 days. The representation asked the Collector to act on an August 2022 order of an earlier Collector and a September 2022 memo of the District Registrar.

Those papers allowed certain plots to be removed from the list of prohibited properties under section 22-A of the Registration Act, 1908.

The petitioners filed the contempt case on 15 October 2025, after the 60 days ran out. The Collector rejected the representation on 26 February 2026, after the contempt case was filed, and again on 8 July 2026 after the court had once more directed reconsideration.

The court found that the Collector's counter-affidavit, which said notices had been issued on receipt of the order, was "palpably false". It also noted that one survey number had been taken off the list while three others stayed on it. It held the disobedience wilful and deliberate and the explanation unsatisfactory.

The Collector argued that a procedure under rule 10A of the Andhra Pradesh Land Reforms (Ceiling on Agricultural Holdings) Rules, 1974 had to be completed first.

The court refused to hear that point in contempt proceedings, relying on Jalim Singh v. Nand Kishore (2026) and Union of India v. Subedar Devassy P.V. (2006), and recorded that the State's appeal against a 2004 tribunal order had been dismissed on 25 April 2026 as time-barred.

The same judge had sentenced the Medak Collector to six months and a fine of Rs 2,000 in a land dispute over 2.22 acres in Bonal village, in a case reported in February 2026. That sentence was also suspended for four weeks.

Gujarat: Rs 1 lakh from his own pocket

Justice M.K. Thakker passed the Gujarat order on 5 November 2026 in Special Civil Application No. 13992 of 2026, Bhumikaben v. Collector, Ahmedabad. The petitioner had applied under section 65 of the Gujarat Land Revenue Code, 1879 to use her agricultural land for non-agricultural purposes. The Collector rejected the application on 11 February 2025.

On 2 March 2026 the High Court quashed that rejection. It held that an inquiry under section 65 is summary and does not decide title or the validity of past transactions, and it let her apply afresh, directing a decision within the statutory period.

She applied again on 7 April 2026. On 6 August 2026 the Collector rejected the application on the same opinions and entries, citing a proposal to the State on whether to appeal against the March judgment. The Collector had not decided it within 90 days.

The State accepted that no appeal had been filed more than seven months after the judgment. It relied on a Revenue Department circular dated 7 October 2026, which the bench noted came after the Collector's decision and only told officers to follow the law laid down by the courts.

The bench said the Collector had acted as "a superpower authority", placing himself above the law by passing an order on the same lines as the one already quashed. It added that "the hardship which is caused to the litigants is required to be compensated by Collector himself from his own pocket".

The August 2026 order was quashed and the application restored for decision within the statutory period. The Collector must deposit Rs 1 lakh with the High Court Registry within one month. If he does not, the State must deposit it and recover it from his salary, and the money goes to the petitioner after verification.

What the law says on contempt

Article 215 of the Constitution makes every High Court a court of record with the power to punish for contempt of itself.

As M. Laxmikanth explains in Indian Polity, the Contempt of Courts Act, 1971 defines civil contempt as wilful disobedience to a judgment, order, writ or other process of a court, or wilful breach of an undertaking given to it.

Section 12 of the Act allows simple imprisonment of up to six months, a fine of up to Rs 2,000, or both. It also allows the court to discharge the accused or remit the punishment on an apology made to its satisfaction, and an apology is not to be rejected only because it is qualified, if made in good faith.

M.P. Jain notes in Indian Constitutional Law that the six-month ceiling is the main curb the Act places on the High Court power, which flows from Article 215 itself. In Pallav Sheth v. Custodian (2001) 7 SCC 549 the Supreme Court held that Parliament may fix the quantum of punishment but cannot abrogate the power.

Wilfulness and the limits of a contempt court

The word that decides most cases is wilful. A person who did not know of the order, or whose order was ambiguous, is not in contempt, but the constitutional commentaries record that where an order is clear, misunderstanding it is no defence, as the Supreme Court held in Anil Ratan Sarkar v. Hirak Ghosh (2002) 4 SCC 21.

A contempt court also does not re-decide the original case. Where an authority doubts that it can comply, the commentaries say it should ask the court for directions rather than put its own reading on the order, which echoes what the Gujarat bench said about approaching the court promptly.

Personal costs and the route of appeal

Imposing costs on an officer personally has support in State of Bihar v. Subhash Singh (1997) 4 SCC 430. A High Court had directed an officer to dispose of a case within two months, and when he did not, it imposed costs on him personally.

The Supreme Court declined to interfere because the delay was 17 months and unexplained, but told High Courts to be circumspect before ordering personal costs.

Section 19 of the Contempt of Courts Act gives a person punished for contempt an appeal as of right, within 30 days. From an order of a single judge the appeal lies to a Division Bench, and the appellate court may suspend the sentence and release the person on bail while it is pending.

The Telangana order suspends the sentence for four weeks. The reports of it, published on 9 November 2026, do not say whether the Ranga Reddy Collector has filed an appeal.