The High Court of Jammu & Kashmir and Ladakh has clarified that a Letters Patent Appeal (LPA) cannot be filed against interim directions issued during contempt proceedings. It reiterated that an appeal under Section 19(1) of the Contempt of Courts Act is available only when a court has actually imposed a punishment for contempt.

A Division Bench of Justices Sindhu Sharma and Shahzad Azeem pointed out that the challenged order dated 01.12.2023 merely required the authorities to submit a fresh compliance report. Since the order neither concluded the dispute nor inflicted any penalty, it could not be appealed.

The Bench explained that Section 19(1) applies only when there is a final decision to penalize a person for contempt. Any procedural direction issued while the case is still being heard cannot be questioned through an appeal under this provision.

Further, rejecting the contention based on Clause 12 of the Letters Patent, the Court noted that only an order which finally determines rights of parties can be termed a “judgment.” Interim or step-by-step directions that do not settle any issues cannot fall within appellate jurisdiction under Clause 12.

Referring to the Supreme Court’s ruling in Midnapore Peoples’ Co-operative Bank Ltd. v. Chuni Lal Nanda and earlier High Court precedents, the Bench concluded that orders merely facilitating contempt proceedings are not appealable.

Case: Commissioner Secretary to Government, Department of Rural Development & PR, Civil Secretariat vs Ryaz Ahmed, 2025