The Andhra Pradesh High Court has emphasized that a mere "paper apology" holds no weight in cases of contempt of court. Described as an apology lacking genuine remorse, regret, or repentance, or used merely as a legal loophole, the court made this assertion while finding Mrs. M. Saraswathi, the Deputy Director of Tribal Welfare, guilty of contempt under Section 12 of the Contempt of Court Act, 1971.

This decision came after the Deputy Director failed to adhere to the court's directive to consider a petitioner's request for promotion to the post of School Assistant (Maths), choosing instead to reject the request.

The Court firmly dismissed the apology as an inadequate defense or excuse for contempt of court. It emphasized that the Deputy Director's eventual compliance with the writ order didn't justify the deliberate disobedience of the initial directive.

The Bench of Justice Ravi Nath Tilhari observed, “Apology cannot be accepted in case it is hollow; there is no remorse; no regret; no repentance, or if it is only a device to escape the rigour of the law. Such an apology can merely be termed as “paper apology”."

Advocate Kishore Kumar represented the Petitioners, while Advocate K. Amrith Raj represented the Deputy Director of Tribal Welfare in a contempt case. The case was filed against S. Saraswathi, the Deputy Director, due to her non-compliance with a Court order dated August 14, 2019. Instead of adhering to the order, the Deputy Director rejected the Petitioner's request, citing the need for clarification from the Director of Tribal Welfare before considering the case.

The Court observed that despite possessing the necessary information to consider the Petitioner's case, the Deputy Director purposefully delayed action. It found the apology offered by the Deputy Director to be insincere, viewing her actions as a deliberate attempt to defy the court's order. The Court stressed the significance of contempt jurisdiction in upholding the honor and authority of the legal system, citing precedents such as Jhareswar Prasad Paul v Tarak Nath Ganguly [(2002) 5 SCC 352] and Kapildeo Prasad Sah v State of Bihar [AIR 1999 SC 3215].

Emphasizing that the power to penalize for contempt of court is essential for maintaining the rule of law and an effective legal system, the Bench reaffirmed the gravity of this judicial responsibility.

The Court highlighted the aspect of public policy within the punishment for civil contempt, emphasizing that the effective administration of justice would be compromised if court orders could be ignored without consequences. This underscores the significance of holding individuals accountable for disregarding court directives to maintain the integrity of the legal system.

Accordingly, the Court allowed the case.

Cause title: P. Satyanarayana Reddy v M. Saraswathi, Deputy Director, Tribal Welfare