Delhi High Court held Hockey India and Bhola Nath Singh guilty of contempt for disobeying orders. Justice Purushaindra Kumar Kaurav stressed misunderstanding cannot justify non compliance.
The Delhi High Court has found Hockey India and its secretary general, Bhola Nath Singh, guilty of contempt for wilfully disobeying judicial directions. The court emphasised that a “misunderstanding” of court orders cannot be used to avoid compliance.
Justice Purushaindra Kumar Kaurav was hearing a contempt petition filed by Syeed Asima Ali, who alleged non-compliance with an earlier interim order dated January 17, 2025.
In its observations, the court said,
“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 emphasised 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,”
Background
The contempt case stemmed from a petition by Syeed Asima Ali, who claimed she was the elected vice president of Hockey India. She had earlier approached the court alleging violations of the National Sports Development Code and challenging the eligibility of the federation’s secretary general.
On January 17, 2025, the Delhi High Court had directed Hockey India to share links to allow Ali to attend all executive board meetings, so that she could participate in the decision-making process.
Ali later alleged that she was not given access to two meetings held on July 4 and July 27, 2025, which led her to file the contempt petition.
Observations of the Court:
The Delhi High Court noted that the law of contempt exists to secure public respect and confidence in the judicial system. It said that contempt jurisdiction is meant to protect the administration of justice and ensure that such authority is not undermined.
The court observed that courts, acting in contempt jurisdiction, purge the “filth” that can enter the stream of justice, which, it said, can get polluted at times. It added that the administration of justice must be protected with the same zeal as is necessary for the foundation of a functioning, civilised, free and egalitarian society.
The court held that it was undisputed that links were not provided on the two occasions, despite a clear and unqualified judicial direction.
Rejecting Hockey India’s defence that Ali had ceased to be a recognised representative due to developments within the Jammu and Kashmir unit, the court ruled that the original order did not place any conditional limitation on her status. It said that parties cannot “read into” court orders qualifications that do not exist, and any doubt regarding compliance should be addressed through modification applications rather than unilateral action.
The court stated:
“The directions are clear, unambiguous, and not susceptible to the kind of mischief the respondents are seeking to engage in,”.
The court also rejected an affidavit filed by the secretary general offering an “unconditional apology.” The High Court noted the apology was filed nearly 250 days after the contempt petition and pointed to procedural shortcomings, including the lack of certification that the contents of the affidavit had been explained to him.
The court further found no real remorse in Singh’s conduct. It observed that an apology cannot be used as a “tactical move” and should reflect genuine contrition.
The court recorded that no effort had been made to purge the contempt. It noted that the minutes of meetings for which links were not provided still remain directly connected to the court’s continuing directions.
It also found that the respondents’ reply attempted to justify their actions and claim that no contempt was made out, while there was no reference to any apology let alone an unconditional one.
The court said,
“Even otherwise, 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 wilful disobedience of the court‘s directions,”.
The High Court further indicated that there may have been a coordinated attempt to get around its order. It pointed to factors such as the timing of communications withdrawing Ali’s recognition, the issue being included in a meeting agenda even before official communication, and the proximity of these developments to the scheduled executive board meeting.
The court noted that these circumstances, “prima facie”, suggested a “concerted design… to surreptitiously circumvent” its directions.
Concluding that the conduct amounted to wilful and deliberate disobedience, the High Court held Hockey India and its secretary general guilty of civil contempt.
The matter has now been listed for May 4, when the court will hear arguments on sentencing. The respondents have also been granted an opportunity to “purge the contempt” before punishment is finally decided.
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