Patna High Court

S.M. Naiyer ImamversusThe State of Bihar

Decided: 22 January 2026
Disposal: DISMISSED
Bench: SUDHIR SINGH RITESH KUMAR

Holding

Since the 2014 order did not contain any specific direction in favour of the petitioner, no contempt of court could be established and the application was dismissed.

Summary

The petitioner, S.M. Naiyer Imam, filed a contempt application before the Patna High Court alleging that the respondents had failed to comply with an order dated 04‑08‑2014 passed in Letters Patent Appeal No. 411 of 2014. During the hearing, the Court asked the petitioner’s counsel to specify which part of the 2014 order remained unimplemented. The counsel could not point to any particular direction that the respondents had ignored. Upon reviewing the 2014 order, the Court found that it contained no specific directive in favour of the petitioner that could be breached. Consequently, the Court held that there was no ground for contempt proceedings and dismissed the application. The dismissal also disposed of any pending applications related to the matter.

Issues considered

Whether the respondents' alleged non‑compliance with the order dated 04‑08‑2014 amounts to contempt of court
Whether a contempt proceeding can be initiated in the absence of a specific direction in the earlier order

Subjects

contempt of court
Letters Patent Appeal
order compliance
High Court
dismissal
procedural law

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              Miscellaneous Jurisdiction Case No.2140 of 2025
                                                       In
                                    Letters Patent Appeal No.411 of 2014
                 ======================================================
                 S.M. Naiyer Imam S/o- Late S.M. Zareef, Founder Secretary Rauf Muslim
                 Jamia Society and its Institution, R/o- Mohalla- Quazina, Banipur, Basuham,
                 P.S- Bahera, District- Darbhanga, Presently residing at 101B, Hyteck castle
                 apartment, Road-3 New Patliputra Colony, P.S- Patliputra, District- Patna.

                                                                           ... ... Petitioner/s
                                                   Versus

           1.    The State of Bihar
           2.    Shri Rajnish Kumar Singh, I.G. Registration, Government of Bihar Patna.
           3.    Prof. Sanjay Kumar Choudhary, Vice-Chancellor, Lalit Narayan University,
                 Darbhanga.
           4.    Dr. Divya Rani Hansda, Registrar, Lalit Narayan University, Darbhanga.
           5.    Sri Anand Kishor, Chairman, Bihar School Examination Board, Patna.
           6.    Sri Pramod Kumar, Secretary, Bihar School Examination Board, Patna.
           7.    Sri Madan Singh Yadav, Regional Director, Eastern Regional Committee,
                 National Council for Teacher Education (NCTE), G-7, Sector-10 Dwaraka,
                 New Delhi-110075.
           8.    S.M Ali Imam S/o- Late S.M Zareef, R/o- Bahera, P.S- Bahera, District-
                 Darbhanga.
           9.    S.M Zafar Imam S/o- Late S.M Zareef, R/o- Bahera, P.S- Bahera, District-
                 Darbhanga.

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :   Mr.Pratap Sharma, Advocate
                 For the LNMU             :   Mr.Bindhyachal Rai, Advocate
                 For the NCTE             :   Mr.Sunil Kumar Singh, Advocate
                 For the Opposite Party/s :   Mr.P.Kr.Sah, AC to GA-5
                                          :   Mr.Rakesh Kr. Ranjan, AC to GA-5
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SUDHIR SINGH
                         and
                         HONOURABLE MR. JUSTICE RITESH KUMAR
                                       ORAL ORDER

                 (Per: HONOURABLE MR. JUSTICE SUDHIR SINGH)

4   22-01-2026                  The present contempt application has been preferred

                   alleging non-compliance of the order dated 04.08.2014 passed
               Patna High Court MJC No.2140 of 2025(4) dt.22-01-2026
                                                           2/2




                         in L.P.A. No. 411 of 2014.

                                      2. During the course of hearing, a specific query was

                         put to the learned counsel for the petitioner as to which part of

                         the aforesaid order had not been complied with. Learned

                         counsel, however was unable to point out any specific direction

                         which has not been complied with.

                                      3. We have perused the order dated 04.08.2014 passed

                         in LPA No. 411 of 2014 and find that no specific direction had

                         been issued in favour of the petitioner, which can be said to

                         have not been complied with by the respondents. As such, no

                         case for initiation of contempt proceedings is made out.

                                      4. Accordingly, the present contempt application

                         stands dismissed.

                                      5. Pending application(s), if any, shall also stand

                         disposed of.



                                                     (Sudhir Singh, J)


                                                     ( Ritesh Kumar, J)

vinita/sujit
U

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