The Delhi High Court has dismissed a writ petition challenging the constitutional validity of Section 20 of the Contempt of Courts Act, 1971, which imposes a one-year limitation period for initiating contempt proceedings. The Division Bench, comprising Chief Justice Devendra Kumar Upadhyaya and Justice Tushar Rao Gedela, observed that the petitioner failed to provide any substantial legal grounds to support the challenge.
The petition was filed by Rajesh Ranjan, an Under Secretary (Grade I, IFS-B) with the Ministry of External Affairs. He participated in the Limited Departmental Competitive Examination (LDCE) and claimed to be an affected party in OA No. 1719/2012 before the Central Administrative Tribunal (CAT), where directions were issued for revising the seniority list of officers.
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CAT, in its judgment dated 29.02.2020, directed that LDCE-promoted officers should not be treated as having been promoted before their actual promotion date. This order was upheld by the High Court and the Supreme Court. Following non-implementation allegations, a contempt petition (CP No. 961/2024) was filed. CAT issued notice, and subsequently, a draft consolidated seniority list was published on 24.02.2025.
Rajesh Ranjan contended that since the contempt petition was filed beyond the one-year limitation under Section 20, its acceptance and the resulting seniority list violated his fundamental rights under Articles 14, 16, and 20 of the Constitution. He further claimed he wasn’t allowed to participate in the contempt proceedings.
However, the Court noted:
“The grounds also appear to disclose the petitioner's grievance in regard to the petitioner not being part of the contempt proceedings and as such being helpless in the said scenario.”
The Court emphasized that constitutional validity challenges must be based on substantial legal grounds, not personal dissatisfaction. It cited key Supreme Court precedents, including:
- Ram Krishna Dalmia v. S.R. Tendolkar
- Subramanian Swamy v. CBI
- Shayara Bano v. Union of India
These judgments highlight that any law must be presumed constitutional unless the challenger clearly proves its invalidity.
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“There is a presumption to the constitutional validity of the provisions of a statute or an enactment... The burden to dislodge or demonstrate the alleged invalidity lies squarely on the person laying challenge.”
The Court found that the petition failed to meet these standards. The petitioner’s arguments were primarily personal grievances and did not raise any issue of manifest arbitrariness, unreasonable classification, or legislative overreach.
Rejecting the plea, the bench concluded:
“These two issues can hardly be said to be a substantial ground much less a ground at all to invalidate the constitutionality of an enactment.”
Accordingly, the High Court dismissed the writ petition in limine, stating that the petition lacked the necessary legal substance even to issue a notice.
Case title: Rajesh Ranjan vs. Union Of India And Ors (W.P.(C) 4965/2025)
