Delhi High Court
Syeed Asima Ali vs Hockey India & Ors on 20 April, 2026
Author: Purushaindra Kumar Kaurav
Bench: Purushaindra Kumar Kaurav
$~2
* IN THE HIGH COURT OF DELHI AT NEW DELHI
CONT.CAS(C) 1119/2025 and CM APPL. 65436/2025
Date of Decision: 20.04.2026
IN THE MATTER OF:
SYEED ASIMA ALI
R/O 44-A WAZIR BAGH,
SRINAGAR, JAMMU & KASHMIR,
INDIA-190008
.....PETITIONER
(Through: Mr. D.N. Goburdhun, Sr. Adv. with Mr. Hemant
Phalpher and Mr. Karishmit Keswani, Advocates)
versus
1. HOCKEY INDIA
THROUGH ITS PRESIDENT
MR. DILIP TIRKEY
C/O HOCKEY INDIA B1/E14,
GROUND FLOOR,
MOHAN COOPERATIVE INDUSTRIAL ESTATE,
MATHURA ROAD, NEW DELHI-110044
2. UNION OF INDIA
THROUGH MINISTRY OF YOUTH AFFAIRS
AND SPORTS
THROUGH SECRETARY (SPORTS),
C WING, SHASTRI BHAWAN
RAJINDER PRASAD ROAD,
NEW DELHI- 110001
3. MR. BHOLA NATH SINGH
SECRETARY GENERAL
C/O HOCKEY INDIA
Signature Not Verified Signature Not Verified
Signed By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 1 of 25 KUMAR KAURAV
B1/E14, GROUND FLOOR,
MOHAN COOPERATIVE INDUSTRIAL ESTATE,
MATHURA ROAD,
NEW DELHI-110044
4. MOHD. FIROZ ANSARI PRESIDENT,
CHHATTISGARH HOCKEY
CHHATTISGARH HOCKEY WARD NO. 2,
BHARKAPARA NEAR
KALI MANDIR CHOWK
CHHATTISGARH,
RAJNANDGAON-491441
.....RESPONDENTS
(Through: Mr. Rajiv Nayyar, Sr. Adv., Ms. Shyel Trehan, Sr. Adv.
with Mr. Rohan Poddar, Mr. Raghav Anand, Mr. Nishikant Singh,
Mr. Shubham Kathuria, Advocates for the respondent nos. 1-3)
CORAM:
HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV
JUDGEMENT
PURUSHAINDRA KUMAR KAURAV, J. (ORAL) INDEX A. FACTUAL MATRIX ...............................................................................3 B. PROCEEDINGS IN THE CONTEMPT PETITION ...........................4 C. SUBMISSIONS MADE BY THE PARTIES .........................................5 D. ANALYSIS ................................................................................................6 (I) THE ARGUMENT OF THE PETITIONER'S POSITION BEING VACATED......9 (II) THE CHEQUERED STORY OF THE MODIFICATION APPLICATIONS ....... 15 (III) THE ―UNCONDITIONAL‖ APOLOGY. .................................................... 18 Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 2 of 25 KUMAR KAURAV (IV) PRINCIPLES GOVERNING CONTEMPT ACTION ...................................... 20 E. CONCLUSIONS .................................................................................... 24 F. ORDER ................................................................................................... 25 The petitioner through this Contempt Petition has moved this Court alleging non-compliance of its order dated 17.01.20251 by the respondents2 and praying for the exercise of its inherent powers under Article 215 of the Constitution of India read with Section 12 of the Contempt of Courts Act, 1971 (hereinafter ―Act‖).
A. FACTUAL MATRIX
2. The petitioner claims to be the elected Vice President of Hockey India, having taken charge of the Executive Board, in accordance with the extant norms, on 01.10.2022. The Writ Petition was filed by her, seeking to bring to the Court's notice purported violations by Hockey India and its administrations, of the judgement and order in Rahul Mehra v. Union of India & Ors.,3 and the National Sports Development Code of India, 2011 (―Sports Code‖).
3. The said Petition alleged, inter alia, that Mr. Bhola Nath Singh, is ineligible to hold any elected office in Hockey India owing to the tenure and age restrictions enumerated in the said Code and as interpreted by the Court in Rahul Mehra. Importantly, the second prayer in the Writ Petition reads as 1 Passed in W.P.(C) 613/2025 (―Writ Petition‖).
2Respondent no. 1 - Hockey India (―Hockey India‖), respondent no. 2 - Mr. Dilip Tirkey, President, Hockey India, and respondent no. 3 - Mr. Bhola Nath Singh, Secretary General, Hockey India.
3W.P.(C) 195/2010, order dt. 16.08.2022, Delhi High Court.
Signature Not Verified Signature Not VerifiedSigned By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 3 of 25 KUMAR KAURAV
under:
―Issue a Writ of Quo Warranto or any other Writ of like nature be passed against the Respondent No. 1 and 3 for removal of the Respondent No. 3 [Mr. Bhola Nath Singh] as its Secretary General from the Respondent No. 1 Hockey India being ineligible to hold any post in Hockey India in terms of the Sports Code and the judgements of this Hon'ble Court;‖ [Emphasis of the Court]
4. Along with the said Writ Petition a C.M. Appl. bearing number 2925/2025 (―CM Application‖) also was filed by the petitioner seeking certain interim reliefs. The Writ Petition along with the CM Application was listed, for the first time, on 17.01.2025. After granting an audience to the parties, hearing them, and considering their case, notice was directed to be issued qua the Writ Petition, and with respect to the prayers made by the petitioner in her CM Application, an interim direction was passed requiring the respondents to provide the requisite links to the petitioner to enable her to participate in all Executive Board Meetings that may be held.
5. The present Contempt Petition alleges willful non-compliance of the aforenoted order of this Court dated 17.01.2025 (―Said Order‖).
B. PROCEEDINGS IN THE CONTEMPT PETITION
6. This Contempt Petition was first listed on 28.07.2025, and the Court while directing for the issuance of notice passed the following order:
―7. After some hearing, it is stated by the learned senior counsel for the petitioner that the directions contained in the interim order dated 17.01.2025 passed in CM APPL.2825/2025 of W.P.(C) 613/2025 shall be complied with and links shall be provided to the petitioner for the purpose of participation in the meetings of the Executive Board of Hockey India.
Further any decision/s that were taken in any previous Executive Board Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 4 of 25 KUMAR KAURAV meetings (for which links were not provided to the petitioner) shall be put in abeyance, till the same is once again considered by the Executive Board in the presence of the petitioner.‖ [Emphasis of the Court]
7. On notice being issued, the respondents filed their common reply dated 05.08.2025. Thereafter, on 06.10.2025, and 26.11.2025 the matter was heard at some length by the predecessor Bench. On 20.01.2026, the Writ Petition was released from ‗part heard', and after appropriate directions being passed by Hon'ble the Chief Justice, the present Contempt Petition along with the Writ Petition was listed before this Bench on 25.03.2026.
8. Vide order dated 25.03.2026, Mr. Bhola Nath Singh, was directed to remain personally present on the following date of hearing. On 27.03.2026, at his request, the hearing was deferred to 07.04.2025. In the interregnum, an affidavit dated 30.03.2026 also came to be filed by him tendering an ―unconditional apology‖. Thereafter, the parties were heard on 07.04.2026 in the presence of Mr. Bhola Nath Singh, and the hearing was deferred for 20.04.2026 for orders.
C. SUBMISSIONS MADE BY THE PARTIES
9. Mr. D.N. Goburdhun, learned senior counsel appearing for the petitioner has carefully taken this Court through the record in the Contempt Petition as well as the Writ Petition. It is his vociferous submission that first, the respondents willfully withheld links for the meetings of the Executive Board on two dates, i.e., 04.07.2025 and 27.07.2025, in willful disobedience of the Said Order; second, the apology tendered by Mr. Bhola Singh is in contravention of the Delhi High Court Rules and Orders, and even its Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 5 of 25 KUMAR KAURAV contents are evasive and prevaricatory in nature; and third, the purported vacation of the petitioner's post of Hockey India was a mischievously and carefully designed plot to attempt to justify non-compliance of the Said Order.
10. Mr. Rajiv Nayyar and Ms. Shyel Trehan, learned senior counsel appearing for the respondents have submitted that first, links were not supplied to the petitioner for the meetings of the Executive Board on 04.07.2025 and 27.07.2025 because the petitioner's parent club i.e., Young Khalsa Sports Club, Srinagar, was de-affiliated from Hockey J&K, and on 03.07.2025, Hockey J&K, informed Hockey India that the petitioner would no longer be a recognized representative of Hockey J&K.
11. Second, it is contended, that owing to the just-mentioned events which transpired after the passing of the Said Order, appropriate modification applications were also moved by the petitioner, one of which, still as on date, remains pending. Third, it is the respondents' case that notwithstanding the aforenoted submissions, their unconditional apology ought to be accepted by this Court.
D. ANALYSIS
12. The prayers made in the CM Application which was disposed of vide the Said Order, inter alia, read as under:
―a) Pass an order directing the Respondent No. 3 to abstain from discharging any duty in the capacity as the Secretary General of the Respondent No. 1 being in violation of the Sports Code as interpreted by this Hon'ble Court in the Rahul Mehra Case; and / or
b) Pass an order directing the Respondent No. 4 to abstain from discharging any duty in the capacity as any committee member of the Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 6 of 25 KUMAR KAURAV Respondent No. 1 being in violation of the Sports Code as interpreted by this Hon'ble Court in the Rahul Mehra Case; and / or include the name;
and / or c. Pass an order directing the Respondent No. 1 to share links of all Executive Board meeting with the Petitioner in advance to enable her to attend and deliberate in all meetings of the Executive Board of Hockey India being the elected vice president of Hockey India and pursuant to the meetings the minutes of the meetings be shared with all members of the Executive Board of Hockey India‖
13. Further, the operative portion of the Said Order, non-compliance of which, is alleged, is extracted as under:
―9. After some hearing, it is agreed that the requisite link shall be provided to the petitioner to enable her to participate in all Executive Board Meetings that may be held. However, learned counsel for the petitioner undertakes, on instructions, that the link will not be shared by the petitioner with any third party nor will the petitioner allow any third party to be privy to the deliberations that take place in the meeting.
10. The present application is disposed of in the above terms.‖ [Emphasis of the Court]
14. A conjoint reading of the prayers made in the CM Application and the directions contained in the Said Order qua the interim application would reveal that this Court on 17.01.2025, had approved and ordered an arrangement, whereby, the respondents were to provide the petitioner the requisite links to participate in all Executive Board Meetings that may be held.
15. The CM Application itself and the prayers made by the litigant who had filed the said application, were disposed of by this Court, in light of the undertaking given by the respondents. The grievance of the petitioner with respect to the functioning, operation and continued occupation of Mr. Bhola Nath Singh, as the Secretary General of Hockey India, for which urgent Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 7 of 25 KUMAR KAURAV reliefs were prayed for under the CM Application were foregone by the petitioner owing to the agreement reached and recorded in the Said Order.
16. The CM Application was neither dismissed, nor allowed in terms of its prayers, but rather, directions were passed, which, with the parties' agreement led to the action of the petitioner being disposed of. The exact agreement involved mutual obligations on the part of the petitioner and the respondents being discharged. While the respondents undertook to provide the requisite links to enable the petitioner to participate in the Executive Board Meetings; the petitioner undertook to not share the link which were to be supplied to her with any third party nor was she allowed to make any third-party privy to the deliberations that took place in the meeting.
17. The Said Order, does not, in any manner whatsoever, qualify the obligation of the respondents to provide the petitioner links only insofar as she remains a Vice President of Hockey India. The agreement so reached between the parties, and as recorded in the Said Order, does not give any such indication.
18. Importantly, para. 3 of the common reply tendered by the respondents to the Contempt Petition, also reveals that the respondents', including Mr. Bhola Nath Singh, understood the Said Order as ―simpliciter‖ directing the meeting notices and links to be issued to the petitioner. The said paragraph reads as under:
―The Order dated 17.01.2025 simpliciter directed that meeting notices and VC links be issued to the Petitioner to enable her participation in meetings of the Executive Board. The Respondents have duly complied with the said direction in respect of meetings held on and before 29.04.2025, including the meeting of that date.‖ Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 8 of 25 KUMAR KAURAV
19. With the Said Order not being modified, challenged, or being tinkered with by any Court of law, and the factum of the respondents' not supplying the petitioner the requisite links on two dates, i.e., 04.07.2025 and 27.07.2025, being undisputed, a positive finding on contempt sufficiently and conclusively can be rendered.
20. After the Court takes notice of a contemnor's ex-facie contemptuous act, one would expect that a prompt, unconditional, and unqualified apology would be tendered. Far from it, the respondents have attempted to justify their willful disobedience through the following ingenious, but woefully inadequate, explanations.
(i) The Argument of the Petitioner's Position Being Vacated
21. While the respondents in their common reply to the Contempt Petition admitted that the Said Order contained ―simpliciter‖ directions requiring links to be provided to the petitioner. It is their case that subsequent to the passing of the Said Order, ―material developments have taken place which directly impacts the Petitioner's eligibility to participate in meetings of the Hockey India Executive Board‖.4 The said developments are:
21.1 Hockey India on 27.06.2025 being informed by Hockey J&K that three of its affiliated clubs, including Young Khalsa Sports Club, Srinagar, of which the petitioner was a member, stands disaffiliated from the membership of Hockey J&K;
21.2 A further communication being made by Hockey J&K dated 4 Para. 4 of the respondents' common reply to the Contempt Petition.Signature Not Verified Signature Not Verified
Signed By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 9 of 25 KUMAR KAURAV
03.07.2025 stating that the petitioner would no longer be recognized as a representative of Hockey J&K with effect from 31.05.2025; and 21.3 Hockey India in its 113th Executive Board Meeting dated 04.07.2025, recognizing that the petitioner's post of Vice President, purportedly becoming vacant owing to her being de-recognized as a representative of Hockey J&K.
22. The respondents' purported interpretation of the Said Order, which caused it to not supply the requisite links, as provided for in Court's directions, can be gleaned from the following paragraphs of their common reply to the Contempt Petition:
―8. ...the Petitioner did not receive the VC links for the Executive Board and Congress meetings solely because she ceased to be a member of Hockey J&K, and consequently ceased to hold a position on the Executive Board of Hockey India under Clause 4.6.2 of its Constitution. Since the VC links and notices are issued only to valid and recognized members of the Executive Board, and the Petitioner no longer held such a position, she was not entitled to receive the same.
...
19. ... The Petitioner's right to participate in the Executive Board meetings was never absolute and is subject to her continued nomination by the affiliated member unit, which in this case is Hockey J&K. In light of communications received from the said unit, and the prevailing inter se dispute within Hockey J&K, which is pending adjudication before competent forums, Hockey India has acted only upon the instructions of the unit and in compliance with its Constitution. It is not open to the Petitioner to unilaterally claim a right to attend EB meetings while bypassing the Constitution of Hockey India.
20. Contents of Para 8 is admitted to the extent that this Hon'ble High Court had, vide order dated 17.0I.2025, directed that due notice and VC links of Executive Board meetings be made available to the Petitioner. However, it is respectfully submitted that the said direction was to be implemented in accordance with the Constitution of Hockey India and subject to the Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 10 of 25 KUMAR KAURAV Petitioner being a recognised representative of the affiliated member unit.
The said direction did not create or confer an independent or absolute right upon the Petitioner to attend such meetings regardless of her status within her parent unit. In this regard, it is reiterated that the Petitioner's right to attend meetings of the Executive Board flows solely from her/ her clubs' nomination by Hockey J& K. Hockey India has acted upon such communication and has not, at any stage, violated the order of this Hon'ble Court."
[Emphasis of the Court]
23. The respondents' delusions of grandeur seem to make them believe that they are sitting in appeal, or are authorities that have powers to interpret, read in, read down, and it appears even overrule the orders passed by this Court. Neither this Court, nor the one above us, made the Said Order ―subject to the Petitioner being a recognised representative of the affiliated member unit.‖ There is not even the faintest of mention, in the directions passed, of qualifications of such kind, that the respondents want to read into the Said Order. The directions are clear, unambiguous, and not susceptible to the kind of mischief the respondents are seeking to engage in.
24. It is not known under which principle or authority known to the law, can a party, to whom orders have been given by a Court, interpret the said orders/directions and claim them to apply only insofar as certain features, qualifications, and aspects remain in existence. It is unfathomable to imagine parties being allowed to decide as to till when directions or orders of the Court are to be complied with. The sanctity of judicial orders may be left in tatters, and may as well be cast to the winds, if parties are allowed to tinker and obfuscate directions passed by the Court.
25. Parties cannot justify non-compliance of Court directions claiming to Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 11 of 25 KUMAR KAURAV have misunderstood the said orders.5 If at all there is a genuine bona fide belief in the mind of a litigant/party that owing to subsequent developments, compliance of directions contained in a Court's order ought to be modified, the appropriate recourse is to file an appropriate action seeking clarification/modification of the order of the Court. The latter part of the judgement details the chequered-story of the respondents' modification applications. As of now, it may be briefly noted, that no application for clarification/modification of the Said Order was ever filed by the respondents.
26. If the specific direction does not provide a qualification, caveat or time-period, the party to whom the order is being given, is no one to add such chains and limitations to them.
27. However, on the facts of the instant case, a deeper level of scrutiny is also warranted into the purported ―material developments‖ highlighted by the respondents. As noted above, as per the pleaded case of the respondents' Hockey J&K had sent two communications dated 27.06.2025 and 03.07.2025 to Hockey India stating, inter alia, that it had resolved that the petitioner would no longer be recognized as a representative of Hockey J&K. In furtherance of the two communications sent by Hockey J&K, the Hockey India in its 113th Executive Board Meeting dated 04.07.2025, recognizing that the petitioner's post of Vice President, purportedly becoming vacant owing to her being de-recognized as a representative of Hockey J&K, resolved to nominate one Ms. Shaista Shafi as the Vice 5 Kapildeo Prasad Sah v State of Bihar, (1999) 7 SCC 569 and Anil Ratan Sarkar v. Hirak Ghosh, (2002) 4 SCC 21.
Signature Not Verified Signature Not VerifiedSigned By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 12 of 25 KUMAR KAURAV
President of Hockey India.6
28. Peculiarly, however, the notice for the 113th Executive Board Meeting of Hockey India, issued by Mr. Bhola Nath Singh on 26.06.2025 at 10:56 PM,7 records as Agenda No. 14 for the Executive Board Meeting, to be ―Discussion on the resolution passed by Hockey Jammu & Kashmir‖. The actual minutes of the said board meeting dated 04.07.2025, do in fact under Agenda No. 14 discuss the resolutions of Hockey J&K pertaining to the petitioner's representation in Hockey India.
29. Thus, prima facie, it appears that Mr. Bhola Nath Singh, while sending its notice dated 26.06.2025 at 10:56 PM, was aware of the communications which Hockey J&K was to send in its letters dated 27.06.2025 and 03.07.2025. It is difficult to comprehend how, without some degree of collusion, the agenda for Hockey India's Executive Board Meeting could include discussion on the developments in Hockey J&K, even before they were communicated.
30. It may be mentioned that during the course of the hearing, in the present of Mr. Bhola Nath Singh, the aforesaid discrepancy was highlighted by the learned senior counsel for the petitioner and upon the same being put by the Court to the respondents', there was no specific reply that was forthcoming.
31. Additionally, emphasis must also be placed on the eerie timing of Hockey J&K's communication dated 03.07.2025, which was sent to Hockey 6 Annexure A (Colly.), common reply of the respondents' to the Contempt Petition.
7Annexure P-2, Contempt Petition.
Signature Not Verified Signature Not VerifiedSigned By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 13 of 25 KUMAR KAURAV
India, one day prior to its 113th Executive Board Meeting, the VC link for which was to be supplied to the petitioner as per the Said Order. The respondents' in their common reply to the Contempt Petition have not mentioned the mode in which they received the said communication, nor the exact date of its receipt. However, since the communication was in the form of a letter, it is also doubtful as to whether Mr. Bhola Nath Singh actually received the same before the Executive Board Meeting of Hockey India took place.
32. The communication dated 03.07.2025, also, for some reason unknown to the Court, seems to specifically require the President,8 and Secretary General of Hockey India i.e., Mr. Bhola Nath Singh, to ensure that the petitioner is not permitted to represent Hockey J&K in either on the Executive Board or at any Annual General Meeting of Hockey India.
33. Prima facie, the aforenoted actions of Hockey India and Hockey J&K, are indicative of a concerted design on the part of the respondents' and others to surreptitiously circumvent the direction passed by the Court. Such conduct cannot be countenanced in any manner. While the Court in this Contempt Petition is not examining the validity of the petitioner's ouster from Hockey India, it is constrained to observe that something is seriously rotten in the Hockey India Federation.
34. It also becomes evident from the orders passed by the Court in these petitions that, whether the petitioner would be disentitled to participate in the meetings of the Executive Board on account of the purported vacation of 8 Respondent no. 2.
Signature Not Verified Signature Not VerifiedSigned By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 14 of 25 KUMAR KAURAV
her post was never an issue considered by the Court.
35. In any case, if at all there was a doubt in the mind of the respondents' as to whether or not it was under an obligation to provide links to the petitioner for participating in the Executive Board Meetings, the consequence of providing the link, even if the same was unwarranted, were not such, that they would be considered as irreparable or extra-ordinary.
36. It is, therefore, clear that the respondents cannot defend their impugned actions on grounds that the petitioner purportedly stood disqualified from Hockey India and her position of Vice President became vacant.
(ii) The Chequered Story of the Modification Applications
37. Two modification applications preferred by the respondents' have been relied upon by Mr. Nayyar and Ms. Trehan, to impress upon the Court the bona fide, prompt, and respectful attitude of the respondents. First is C.M. Appl. 48089/2025 dated 05.08.2025 in the Contempt Petition, which sought modification of the following portion of para. 7 of the order dated 28.07.2026 passed in the Contempt Petition:
―...any decision/s that were taken in any previous Executive Board meetings for which links were not provided to the petitioner) shall be put in abeyance, till the same is once again considered by the Executive Board in the presence of the petitioner.‖9
38. A bare perusal of the aforenoted would reveal that it does not have any connection with the direction contained in the Said Order, pertaining to the petitioner being required to be supplied with the requisite links.Signature Not Verified Signature Not Verified
Signed By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 15 of 25 KUMAR KAURAV
39. The second modification application is C.M. Appl. 65436/2025 dated 14.10.2025 in the Contempt Petition. The said application seeks the modification of the order dated 28.07.2025 passed in the Contempt Petition to ―record that the said directions permitting the Petitioner to receive notice and participate in meetings of the Executive Bord of Hockey India shall stand recalled in view of the disaffiliation of Young Khalsa Sports Club, Srinagar and consequent cessation of the Petitioner's membership of the Executive Board.‖
40. In the said modification application, the respondents' have also, inappropriately pleaded that it has not committed contempt of Court. The exact phrasing of the pleading is also quite similar to that made in the common reply submitted by the respondents' to the contempt petition. The relevant portion and the comparison is made as under:
C.M. Appl. 65436/2025 Common reply of respondents to the Contempt Petition ―10. ... As per the established practice and ―8. ... Since the VC links and notices are constitutional framework of Hockey India, issued only to valid and recognized notices and VC links for meetings of the members of the Executive Board, and the Executive Board and Congress are issued Petitioner no longer held such a only to valid and recognized members of the position, she was not entitled to receive said bodies. Since the Petitioner ceased to the same.‖ hold such a position, she became ineligible to receive further communications or meeting links.
―10. ...The non-issuance of VC links, ―8. ...The non-receipt of VC links, therefore, was not a result of any deliberate therefore, was not due to any deliberate or mala fide act on the part of Hockey India, or malafide act on the part of Hockey but a natural and inevitable consequence of India, but a natural and necessary 9 Para. 3 of the C.M. Appl. 48089/2025 dated 05.08.2025 in the Contempt Petition.Signature Not Verified Signature Not Verified
Signed By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 16 of 25 KUMAR KAURAV
her cessation from membership, duly consequence of her cessation from
intimated by the concerned State Member membership, duly informed by the
Unit. In these facts and circumstances, no act concerned State Member Unit. In these
of defiance or wilful disobedience of this facts and circumstances, it is respectfully
Hon'ble Court's order dated 17.01.2025 and submitted that no contempt can be said
28.07.2025 can be attributed to Hockey to have been committed by Hockey India.
India.‖ The Petitioner's exclusion from
communications pertaining to the
meetings stemmed from her
disqualification under the Constitution of
Hockey India and not from any act of
defiance or willful disobedience of the
order dated 17.01.2025 passed by this
Hon'ble Court.‖
41. It, thus, becomes clear as day, that the modification application was only moved by the respondents' because the Contempt Petition was filed by the petitioner. Moreover, the said application was more a strategic legal maneuver, than a bona fide attempt by a party to seek clarification/modification of the Court's order.
42. Qua the said modification application, it may also be considered that--first, it was preferred after the act of contempt viz. the non-supply of links to the petitioner for meetings dated 04.07.2025 and 27.07.2025 had already taken place; second, it sought modification not of the Original Order but of the order dated 28.07.2025 passed in the Contempt Petition. Third, in the said modification application, the respondents' have pleaded that the petitioner is ineligible to receive further communications or meeting links. If that were the case, there does not seem to be any justification for filing the modification application.
43. Further, on 28.07.2025, when notice was directed to be issued on the Contempt Petition, this Court took exception to the alleged disobedience and Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 17 of 25 KUMAR KAURAV had passed certain directions upholding and reiterating the directions contained in the Said Order. On the said date as well, the respondents did not apprise the Court of any vacation of petitioner's post in Hockey India. It may be reiterated that as per the respondents' version of the story, communications were received by it on 27.06.2025 and 03.07.2025 from Hockey J&K. The modification application bearing no. 65436/2025, however, was filed on 14.10.2025 i.e., more than 3 months after receiving the latter of the two communications.
44. It is, thus, clear that the modification applications preferred by the respondents cannot defend its impugned actions.
(iii) The "unconditional" apology.
45. In the Contempt Petition which was filed on 21.07.2025, Mr. Bhola Nath Singh has tendered his affidavit dated 30.03.2026, containing his ―apology‖. Approximately after 250 days from the filing of the petition, the said apology-affidavit has been presented to the Court. Even this affidavit was not tendered by Mr. Bhola Nath on the first day he was directed to be physically present i.e., on 27.03.2026.
46. Rather, it appears, that after attending Court on 27.03.2026, Mr. Bhola Nath Singh, and his advisors, thought it fit to furnish an apology-affidavit, before the next date of hearing. After interacting and questioning him on 27.03.2026 and 07.04.2026, it was told to this Court by Mr. Bhola Nath Singh himself that he does not understand or speak the English language. However, the affidavit tendering the ―unconditional‖ apology has been written/typed in English. The verification in the said apology-affidavit reads Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 18 of 25 KUMAR KAURAV as under:
―VERIFICATION Verified at Ranchi, Jharkhand on this 30th day of March 2026 that the contents of my above affidavit are true and correct to my knowledge. no part of it is false and nothing material has been concealed therefrom.‖
47. There is, thus, no certification by the attesting officer that the contents of the affidavit have been read and explained to Mr. Bhola Nath Singh in a language that he understands. The same is the requirement under paragraph 14, Chapter 12-B, Volume IV of the High Court Rules and Orders. The said provision is extracted below, for reference:
―14. Attesting officer's duty.
If any person making an affidavit appears to the Court, Magistrate, or other officer administering the oath or affirmation, to be ignorant of the language in which it is written, or to be illiterate, or not fully to understand the contents of the affidavit, such Court, Magistrate, or officer shall cause the affidavit to be read and explained to him in a language which both he and such Court, Magistrate or officer understand; either doing so himself, or causing another person to do so in his presence. When an affidavit is read and explained as herein provided, such Court, Magistrate or other officer as aforesaid shall certify in writing at the foot of the affidavit that it has been so read and explained, and that the declarant seemed perfectly to understand the same at the time of making it.‖
48. Therefore, the affidavit dated 30.03.2026 filed on behalf of Mr. Bhola Nath Singh cannot be appreciated, considered, or looked at by this Court.
After interacting with Mr. Bhola Nath Singh, it has also become apparent that he does not seem to have any idea as to the import and meaning of the words typed/written in the apology-affidavit which bears his signature. It may also be noted that the common response tendered by the respondents to the Contempt Petition has also been verified by Mr. Bhola Nath Singh, the affidavit and verification furnished in relation thereto also suffers from the Signature Not Verified Signature Not Verified Signed By:NEHA CHOPRA Signed Signing Date:20.04.2026 By:PURUSHAINDRA 19:55:18 Page 19 of 25 KUMAR KAURAV same infirmity.
49. However, an oral apology has been tendered by Mr. Bhola Nath Singh, which the Court takes on record. The same is, however, found to be woefully inadequate. The facts and dates as narrated and emphasized above would indicate a complete lack of remorse on the part of Mr. Bhola Nath Singh which cannot be condoned by this Court. The Supreme Court, in T. Godavarman Thirumulpad v. Ashok Khot and Anr.,10 has held that an apology is an act of contrition and regret, and ought to be tendered at the earliest possible opportunity. Similarly, in Anil Ratan Sarkar, the Supreme Court held that the belated apology tendered by the contemnors was a ‗tactful move' adopted when they were in a tight corner.
50. Additionally, this Court must also make a mention of the manner in which Mr. Bhola Nath Singh has conducted himself. After having interacted with the man in flesh on two separate dates, his demeanor, tone, and attitude does not evince the required apologetic contrition/sincerity expected out of a contemnor.
51. It is, therefore, clear that the affidavit-apology of Mr. Bhola Nath Singh is, meaningless, akin to dead letters, and is being discarded. The oral apology, conduct and behavior of Mr. Singh also does not add to his defense.
(iv) Principles governing contempt action
52. The Court has an inherent power to punish for its own contempt. The 10 (2006) 5 SCC 1.
Signature Not Verified Signature Not VerifiedSigned By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 20 of 25 KUMAR KAURAV
same is recognized under Article 215 of the Constitution of India. The said power inheres in the judiciary as ―to discharge its primary duty to maintain a fair and effective administration of justice, it follows that the judiciary must as an integral part of its constitutional function have the power and the duty to enforce its orders and to protect the administration of justice against contempts which are calculated to undermine it.‖11
53. Sawant J. in the most eloquent of terms, detailed the purpose and significance of contempt jurisdiction in the following words:
"The rule of law is the foundation of a democratic society. The Judiciary is the guardian of the rule of law. Hence judiciary is not only the third pillar, but the central pillar of the democratic State. In a democracy like ours, where there is a written Constitution which is above all individuals and institutions and where the power of judicial review is vested in the superior courts, the judiciary has a special and additional duty to perform, viz. to oversee that all individuals and institutions including the executive and the legislature act within the framework of not only the law but also the fundamental law of the land."12
54. Courts acting under contempt jurisdiction undertake to purge the filth stuck in the stream of justice which flows throughout the country, and does, on occasions, get polluted. Administration of justice ought to be protected with as much zeal as the same is foundational to the existence of a functioning civilised free and egalitarian social order. The law of contempt is intended to secure public respect and confidence in the judicial process and provides the much-needed sanction for any act or conduct which is likely to destroy or impair such respect and confidence.13 11 Gilbert Ahnee v. Director of Public Prosecutions, (1999) 2 AC 294, per Lord Steyn at 303. 12 Re: Vinay Chandra Mishra, (1995) 2 SCC 584.
13Samaradtiya Pal, The Law of Contempt, 6th Ed., Lexis Nexis, Part I, Chapter 1.
Signature Not Verified Signature Not VerifiedSigned By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 21 of 25 KUMAR KAURAV
55. Samaraditya Pal has observed,14 after relying the pronouncement of the Supreme Court in Kapildeo Prasad Sah v State of Bihar,15 that ―disobedience of the court's order strikes at the very root of the rule of law on which the system of Indian governance is based. The law of contempt can, therefore, be identified as one of the major props holding together the basic structure of our Constitution.‖
56. The provisions of the Contempt of Court Act, 1971 (hereinafter ―Act‖) also detail the action for contempt. Under Section 2(b) of the Act, ―civil contempt‖ is defined in the following terms:
―2. Definitions --In this Act, unless the context otherwise requires,-- ...
(b) "civil contempt" means wilful disobedience to any judgment, decree, direction, order, writ or other process of a court or wilful breach of an undertaking given to a court‖
57. In Ashok Paper Kamgar Union v. Dharam Godha,16 the Supreme Court has held that willful disobedience of a judicial order would mean any act or omission which is done voluntarily and intentionally and with the specific intent to do something the law forbids or with the specific intent to fail to do something the law requires to be done, that is to say with bad purpose either to disobey or to disregard the law. Whether or not the contemnor has in fact, willfully disobeyed the Court-order is to be decided taking into account the facts of each case.
58. The Supreme Court in Kapildeo Prasad Sah v. State of Bihar (supra), observed that for holding a person guilty of contempt, the Court must be 14 Supra.
15(1999) 7 SCC 569.
Signature Not Verified Signature Not VerifiedSigned By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 22 of 25 KUMAR KAURAV
satisfied that the disobedience of the Court's order must be deliberate or contumacious. Judicial orders are to be properly understood and complied with, and even negligence and carelessness may amount to willful disobedience if the implications of the Court order are brought to the attention of the contemnor. Further, in Anil Ratan Sarkar v. Hirak Ghosh,17 it was, importantly, declared that misunderstanding or own understanding of Court orders is not a permissible defence against contempt action. When the Court order is clear and unequivocal, the same ought to be adhered to without any tinkering.
59. The Court in Patel Rajnikant Dhulabhai v. Patel Chandrakant Dhulabhai,18 had held that while punishing a person for contempt of Court is a drastic step which should normally not be resorted to, there exists a duty on the Court to uphold and maintain its dignity and the majesty of law. If contempt action is required for the said purpose, Courts ought to exercise its powers under the Act.
60. In light of the discussion above, the Court is of the opinion that the impugned action of the respondents, specifically, Mr. Bhola Nath Singh, in willfully disobeying Court orders, in the facts of the present case, undermines the majesty of the Court. It must be emphasized that Mr. Bhola Nath Singh, the General Secretary of Hockey India, is administering a National Sports Federation, an authority that functions under the aegis of, and receives funds from, the State. For such an authority, non-compliance of the orders of the Court, is no less than an administrative sin.
16(2003) 11 SCC 1.
Signature Not Verified Signature Not VerifiedSigned By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 23 of 25 KUMAR KAURAV
61. No endeavor has ever been made to purge the contempt. The minutes of the meeting, links for which were not provided to the petitioner, still stares at the face of the Court's subsisting directions. The common reply furnished by the respondents to the Contempt Petition, attempted to justify its actions and claimed that no contempt is made out. There was not even a whisper of an apology, let alone an unconditional apology.
62. Even otherwise, also, an unconditional apology, unlike the holy water from the Ganges, cannot purify the respondents, specifically Mr. Bhola Nath Singh, of his conscious, concerted, deliberate and willful disobedience of the Court's directions.
E. CONCLUSIONS
63. On the conspectus of the entire controversy and the foregoing discussion of law, the following conclusions are being reached by the Court:
63.1 The Said Orders required the respondents to provide the petitioner with the requisite links to enable her to participate in all Executive Board Meetings that may be held;
63.2 The respondents failed to provide the petitioner with links for the Executive Board Meetings dated 04.07.2025 and 27.07.2025 to the petitioner;
63.3 The non-supply of links to the petitioner cannot be justified as-- first, purported subsequent events did not excuse the 17 (2002) 4 SCC 21.18
(2008) 14 SCC 561.
Signature Not Verified Signature Not VerifiedSigned By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 24 of 25 KUMAR KAURAV
respondents from their obligation to provide links to the petitioner in compliance of the Said Order; second, no application, at all, has been moved by the respondents' seeking modification of the Said Order, and to seek the leave of the Court to not comply with the Said Order; and third a bona fide genuine apology was also not tendered by the respondents;
63.4 The respondents' act of not providing the links as noted in para. 62.2., was a willful act of disobeying/not complying with the Said Order of the Court; and 63.5 The manner in which Hockey India and specifically Mr. Bhola Nath Singh has conducted himself through the course of the present proceedings amounts to a clear case of contempt of Court.
F. ORDER
64. This Court finds the respondents, and specifically Mr. Bhola Nath Singh, Secretary General of Hockey India, guilty of committing contempt of Court, by willfully disobeying/not complying with the order dated 17.01.2025.
65. List on 04.05.2026 for hearing the parties on the question of sentencing. Liberty is granted to the respondents to purge the contempt and undertake such measures as found fit.
PURUSHAINDRA KUMAR KAURAV, J
APRIL 20, 2026/Rao
Signature Not Verified Signature Not Verified
Signed By:NEHA CHOPRA Signed
Signing Date:20.04.2026 By:PURUSHAINDRA
19:55:18
Page 25 of 25 KUMAR KAURAV