The Allahabad High Court has referred the conduct of senior IAS officer and Devi Patan Mandal Commissioner Durga Shakti Nagpal to the court competent to examine criminal contempt matters, after a subordinate judicial officer alleged that the bureaucrat attempted to exert pressure on her over a pending civil dispute.
A Bench of Justice Syed Qamar Hasan Rizvi observed that the tenor and language attributed to the telephonic conversation between Nagpal and Civil Judge (Senior Division), Gonda, Shabina Khan, prima facie conveyed an impression that an attempt was made to influence the Presiding Officer in relation to a matter pending before her court.
The controversy arose in connection with a civil suit instituted in 1997 concerning government land. The proceedings have remained pending for nearly three decades and had reached the stage of recording evidence. During the proceedings, the judicial officer informed the District Judge, Gonda, about an alleged telephone conversation with Commissioner Nagpal and sought transfer of the case to another court.
According to the judicial officer’s communication dated August 4, 2026, Nagpal had called her on July 15 while she was on leave. The officer alleged that the Commissioner questioned her about the duration of her leave and subsequently objected to her not answering the phone earlier. She further alleged that the Commissioner invoked her status as a senior IAS officer, threatened to complain to the High Court and indicated that the case could be transferred.
The judicial officer perceived the conversation as an attempt to intimidate her and exert undue influence in relation to the pending proceedings. Following her representation, the District Judge withdrew the suit from her court and transferred it to another court of equivalent jurisdiction.
The transfer rendered the original transfer application before the High Court infructuous. The Bench consequently observed that the application had “lost its efficacy” since the relief sought had already been granted by the District Judge. However, the Court made it clear that the alleged conduct of the Commissioner could not be ignored merely because the case itself had been transferred.
Nagpal, for her part, did not dispute that the telephone conversation had taken place but offered a different explanation for it. She stated that after assuming charge of the division in April 2026, she had learnt that litigation concerning government land earmarked for construction of the Commissioner’s office had remained pending for decades. She claimed that her call was limited to enquiring about the judicial officer’s leave and that the pending case was not discussed during the conversation.
The Commissioner further stated that she subsequently approached the District Judge with a request that the long-pending matter be taken up for expeditious disposal.
The High Court, however, held that the allegations contained in the judicial officer’s letter warranted judicial scrutiny. Justice Rizvi observed that the High Court has a duty to protect subordinate courts from being “insulted or pressurized” and to ensure that judicial officers retain the institutional freedom to discharge their adjudicatory functions without fear or external influence.
The Bench emphasised that any conduct calculated to put pressure on a court or its Presiding Officer has the potential to obstruct the administration of justice. It also referred to the Supreme Court’s ruling in In Re: Ajay Kumar Pandey (1996), wherein the Court had considered the implications of threats to initiate complaints against judicial officers concerning the discharge of their judicial functions.
Against this backdrop, the High Court concluded that the allegations made against Nagpal prima facie warranted consideration under the law of criminal contempt. It directed that the matter be placed before the appropriate court dealing with criminal contempt proceedings, subject to directions from the Chief Justice or the senior Judge concerned.
The order underscores the judiciary’s institutional responsibility to preserve the independence of subordinate courts and signals that attempts whether direct or indirect to influence judicial decision-making may attract the contempt jurisdiction when they are capable of interfering with the administration of justice.
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