(Prayer in LPA No.43 of 2025: Appeal filed under Clause 15 of the Letters Patent to set aside the order dated 30.07.2025 passed in Cont.P.No.2080 of 2025.

In LPA No.29 of 2025: Appeal filed under Clause 15 of the Letters Patent to set aside the order dated 30.07.2025 passed in Cont.P.No.2080 of 2025.

In LPA No.46 of 2025: Appeal filed under Clause 15 of the Letters Patent to set aside the order dated 13.08.2025 passed in Sub Appl No.932 of 2025 in Cont.P.No.2080 of 2025.)

Sushrut Arvind Dharmadhikari, CJ.

1. These appeals challenge two orders passed by the learned Single Judge in contempt proceedings, viz., (i) the order dated 30.7.2025 passed in Contempt Petition No.2080 of 2025, and (ii) the order dated 13.8.2025, passed in Sub Application No.932 of 2025. By these orders, the learned Single Judge issued directions regarding the administration and performance of daily poojas at the Arulmigu Kaliamman Temple in Parukkal Village, Ariyalur District.

2.1. The dispute concerns the management and right to conduct daily poojas at the Arulmigu Kaliamman Temple, a private temple, located in Parukkal Village, Udayarpalayam Taluk, Ariyalur District. Owing to escalating disputes between local groups over temple administration, police authorities locked the temple premises to maintain public order.

                    2.2. The appellant in LPA Nos.43 and 46 of 2025, Desikan, filed a writ petition in W.P.No.6670 of 2025 seeking a direction to the police authorities to unlock the temple and return the keys to him to perform daily poojas. By an order dated 26.2.2025, the learned Single Judge disposed of the writ petition. The Court permitted one V.Veeramani to perform the daily pooja as a common neutral person. Crucially, the learned Single Judge explicitly relegated all disputing parties to the competent Civil Court to establish and declare their civil rights over the temple.

                     2.3. Aggrieved by the order dated 26.2.2025, the appellant preferred an intra-court appeal in W.A.No.1106 of 2025. On 9.4.2025, a Division Bench of this Court dismissed the writ appeal. The Division Bench held that writ proceedings cannot resolve disputed civil rights or factual questions and affirmed that the parties must approach the Civil Court to crystallize their rights.

                     2.4. The appellant subsequently filed a Special Leave Petition, SLP (C) No.18153 of 2025. On 21.7.2025, the Supreme Court dismissed the SLP, expressly declining to interfere with the order passed by the Division Bench of this Court in view of the liberty already granted to the parties to approach the Civil Court.

                     2.5. Meanwhile, V.Veeramani filed Contempt Petition No.2080 of 2025 before the learned Single Judge, alleging obstruction and non-compliance with the order dated 26.2.2025.

                     2.6. Despite the finality reached regarding the writ order, which relegated the parties to civil court, the learned Single Judge passed an order on 30.7.2025 in the contempt petition, issuing a series of new directives:

                     (a) Appointing four individuals (V.Veeramani, Kannan, V.Annadurai, and K.Sakthivel) to perform daily poojas;

                     (b) Directing the police to hand over safety locker keys to the Revenue Divisional Officer (RDO);

                     (c) Directing the RDO to conduct an enquiry between the rival groups ('A' party and 'B' party) and pass administrative orders within four weeks;

                     (d) Directing the police to immediately open the temple for public worship.

                     2.7. Thereafter, in Sub Application No.932 of 2025 filed in the disposed of Contempt Petition, the learned Single Judge issued further directions on 13.8.2025. The Court recorded that the sanctuary lock was broken open, ordered two sets of new keys to be distributed to 'A' party and 'B' party respectively, and listed the matter for reporting further compliance.

                     2.8. Aggrieved by these directions passed in contempt jurisdiction, the present appeals have been filed.

3. The core question for determination is whether a court exercising contempt jurisdiction can issue fresh, modified, or supplemental directions beyond the original judgment alleged to have been violated.

4. The scope of contempt jurisdiction is well settled. In Sudhir Vasudeva v. M.George Ravishekeran((2014) 3 SCC 373), the Supreme Court clearly delineated the boundaries of contempt powers. At paragraph 19, the Supreme Court held thus:

                     “19. The power vested in the High Courts as well as this Court to punish for contempt is a special and rare power available both under the Constitution as well as the Contempt of Courts Act, 1971. It is a drastic power which, if misdirected, could even curb the liberty of the individual charged with commission of contempt. The very nature of the power casts a sacred duty in the Courts to exercise the same with the greatest of care and caution. This is also necessary as, more often than not, adjudication of a contempt plea involves a process of self-determination of the sweep, meaning and effect of the order in respect of which disobedience is alleged. The Courts must not, therefore, travel beyond the four corners of the order which is alleged to have been flouted or enter into questions that have not been dealt with or decided in the judgment or the order violation of which is alleged. Only such directions which are explicit in a judgment or order or are plainly self-evident ought to be taken into account for the purpose of consideration as to whether there has been any disobedience or wilful violation of the same. Decided issues cannot be reopened; nor can the plea of equities be considered. The Courts must also ensure that while considering a contempt plea the power available to the Court in other corrective jurisdictions like review or appeal is not trenched upon. No order or direction supplemental to what has been already expressed should be issued by the Court while exercising jurisdiction in the domain of the contempt law; such an exercise is more appropriate in other jurisdictions vested in the Court, as noticed above. The above principles would appear to be the cumulative outcome of the precedents cited at the Bar, namely, Jhareswar Prasad Paul v. Tarak Nath Ganguly, (2002) 5 SCC 352; V.M. Manohar Prasad v. N. Ratnam Raju, (2004) 13 SCC 610, Bihar Finance Service House ConstructionCoop. Society Ltd. v. Gautam Goswami. (2008) 5 SCC 339, and Union of India v. Subedar Devassy PV, (2006) 1 SCC 613.”

                     [emphasis supplied]

5. The law laid down by the Supreme Court establishes three clear rules:

                     (i) A court exercising contempt jurisdiction cannot travel beyond the explicit terms of the original order;

                     (ii) Contempt jurisdiction cannot be used to issue fresh, additional, or supplemental directions to expand the original order; and

                     (iii) Contempt proceedings cannot re-examine or modify issues already decided, nor can they usurp corrective jurisdictions like review or appeal.

6. The original order dated 26.2.2025 passed in W.P.No.6670 of 2025 relegated the parties to the Civil Court to adjudicate their administrative and pooja rights, while permitting one individual to conduct basic daily poojas in the interim. That order relegating the parties to the civil court was upheld by the Division Bench and affirmed by the Supreme Court.

7. Once the main writ petition was disposed of and affirmed in appeal, the role of the contempt court was to determine whether there was willful disobedience of the explicit direction in the writ order. However, the learned Single Judge traveled far beyond the original order. In the order dated 30.7.2025, the learned Single Judge created a fresh mechanism for temple administration. He appointed three additional poojaris, instructed revenue authorities to conduct administrative enquiries and passed distinct management directions regarding temple keys and lockers. In the subsequent order dated 13.8.2025, further instructions were issued on key custody and enforcement.

8. In our considered opinion, passing the aforesaid fresh directions directly violates the law laid down by the Supreme Court in Sudhir Vasudeva (supra). The contempt court effectively supplemented and altered its original judgment by creating a new administrative framework for the temple. This exceeded the court's jurisdiction under the Contempt of Courts Act, 1971.

9. We are, therefore, of the firm view that the learned Single Judge exceeded his contempt jurisdiction by issuing fresh and supplemental directions that went beyond the four corners of the original writ order. Consequently, the impugned orders cannot be sustained in law.

10. In the result, these appeals are allowed. The order dated 30.7.2025 passed in Contempt Petition No.2080 of 2025, and the order dated 13.8.2025 passed in Sub Application No.932 of 2025, are set aside.

11. The parties are at liberty to work out their remedies and establish their rights before the competent Civil Court as originally directed. We make it clear that the Civil Court shall decide the pending suit on its own merits uninfluenced by any observations made by this court.

There shall be no order as to costs. Consequently, connected interim applications stand closed.