Patna High Court
Rabia AnjumversusThe State of Bihar through the Chief Secretary
- Decided
- Disposal
- DISPOSED
- Bench
- RAJIV ROY
Holding
The later order issued by the Municipal Commissioner fulfilled the earlier court direction, rendering the contempt petition untenable.
Summary
Petitioner Rabia Anjum and her husband filed a contempt petition alleging that the Patna Municipal Commissioner had willfully failed to comply with a July 2, 2024 order directing the Commissioner to address their grievance by December 31, 2024. The contempt petition was filed on September 24, 2025, but no show‑cause notice was issued. On January 16, 2026, the Municipal Commissioner produced a reasoned order dated March 10, 2026, indicating compliance with the earlier direction. The court observed that the issuance of this order satisfied the earlier directive and therefore there was no longer any ground for contempt. Consequently, the contempt petition (MJC No. 3372 of 2025) was disposed of.
Issues considered
- Whether the Patna Municipal Commissioner’s failure to issue an order by the stipulated date amounted to contempt of the earlier court order
- Whether the subsequent order dated 10‑03‑2026 defeats the contempt petition
Subjects
- contempt of court
- civil writ jurisdiction
- municipal corporation
- compliance with court order
- high court
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
Miscellaneous Jurisdiction Case No.3372 of 2025
In
Civil Writ Jurisdiction Case No.1914 of 2024
======================================================
1. Rabia Anjum Wife of Syed Shabbir Alam, C/o Wasimuddin Ahmad Anjum,
Plot No. 180A Patliputra Colony, P.S. Patliputra Colony, Town and District-
Patna.
2. Syed Shabbir Alam, Son of Late Syed Mahfooz Alam, Resident of C/o
Wasimuddin Ahmad Anjum, Plot No. 180A Patliputra Colony, P.S. Patliputra
Colony, Town and District-Patna.
... ... Petitioner/s
Versus
1. The State of Bihar through the Chief Secretary Old Secretariat, Patna.
2. Mr. Animesh Kumar Parashar, Municipal Commissioner, Patna Municipal
Corporation, Maurya Lok, Patna.
3. S.N. Ziasuddin Gilani, Son of Rafiuddin Gilani, Resident of 172D, P.S.
Patliputra Colony, Patna, Town and District-Patna, Bihar.
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Ravindra Kr. Shukla, Advocate
For the State : Mr. Manoj Kr. Ambastha, SC-26
Mr. Tripurari Nath Ambastha, AC to SC-26
For the Opposite Party/s : Mr. Prasoon Sinha, Sr. Advocate
Mr. Prabhat Kumar, Advocate
======================================================
CORAM: HONOURABLE MR. JUSTICE RAJIV ROY
ORAL ORDER
5 11-03-2026 Heard Mr. Ravindra Kr. Shukla, learned counsel for
the petitioner and Mr. Prasoon Sinha, learned Senior counsel for
the Patna Municipal Corporation (for brevity ‘the PMC’).
2. The present petition has been preferred for the
following relief(s):
“for initiating contempt proceeding
against the contemnor opposite party for willful
and deliberate violation/disobedience of the order
Patna High Court MJC No.3372 of 2025(5) dt.11-03-2026
2/2
dated 02.07.2024 passed in CWJC No. 1914 of
2024.”
3. The CWJC No. 1914 of 2024 (Rabia Anjum vs. The
Municipal Commissioner, Patna Municipal Corporation & Anr.)
was disposed of on 02.07.2024 in which the direction was
issued to the Municipal Commissioner, Patna Municipal
Corporation to look into the grievance of the petitioners and
pass an appropriate order by 31.12.2024.
4. Though the contempt petition was filed on
24.09.2025 and no show cause was filed till the matter was
taken up on 16.01.2026, today on call, Mr. Prasoon Sinha has
provided the order dated 10.03.2026 passed by the Municipal
Commissioner, Patna Municipal Corporation by which a
reasoned order has been passed.
5. In that background, since an order has been passed
granting liberty to the petitioners to agitate the matter if they so
want, MJC No. 3372 of 2025 stands disposed of.
(Rajiv Roy, J)
Adnan/-
U
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