Advocates’ Strikes Stalling Revenue Cases Will Invite Contempt: Allahabad HC Warns Bar Office Bearers

The Allahabad High Court has held that if advocates’ strikes delay revenue cases in Uttar Pradesh, the office bearers of the concerned Bar Associations will be liable for contempt of court.

The bench of Justice Arun Kumar Singh Deshwal passed the order in a petition filed by two litigants from Balrampur, who complained that their case for division of agricultural holdings under Section 116 of the Uttar Pradesh Revenue Code, 2006, had remained pending for more than two years despite a statutory mandate requiring its disposal within six months.

The petitioners sought a direction to the Sub Divisional Magistrate (SDM), Utraula, to decide a 2022 case pending since November 11, 2022. They argued that Rule 109(10) of the U.P. Revenue Code Rules, 2016 obligates the SDM to make every effort to conclude such proceedings within six months, except for legally justified reasons. However, no progress had been made on their case even after repeated adjournments.

Justice Deshwal observed that the statutory timeline was not merely directory but formed part of a larger judicial effort to ensure timely adjudication of revenue disputes, an effort crystallised in the High Court’s 2023 judgment in Daya Shankar v. State of U.P..

That judgment not only reiterated the binding nature of statutory time limits but also laid down a comprehensive framework requiring revenue authorities to record reasons for delays, disposing several categories of revenue disputes within fixed timelines, and subjecting erring officers to contempt for unexplained or negligent delay.

Upon examining the order sheet of the petitioners’ case, court noted that the primary reason the proceedings had not advanced was the “continuous strike” by the Bar Association of Tehsil Utraula. Although some adjournments were occasioned by the presiding officer’s unavailability, court found that the dominant cause of delay was the boycott by advocates.

Such conduct, the court held, hindered the administration of justice and directly violated the timeline mandated by Rule 109(10), as well as the High Court’s own binding directives in Daya Shankar.

Court clarified that in circumstances where delay is caused by the revenue authorities, contempt liability may arise against the concerned officers. However, where delay stems from the advocates’ strike, contempt will lie not against the presiding officer but against the office bearers of the relevant Bar Association.

In the present matter, court expressly held that it was the Bar Association of Tehsil Utraula that was prima facie in contempt of the Daya Shankar directions.

Directing the SDM, Utraula, to finally dispose of the long-pending case within six months, court made it clear that any adjournment caused due to continuing strikes by advocates would render the Bar Association’s office bearers liable for contempt proceedings.

Stressing that the issue affects the public at large, particularly poor farmers who depend on timely resolution of land disputes, court issued a sweeping direction for the entire State.

Case Title: Parshuram And Another vs. Sub Divisional Magistrate, Utraula, Balrampur And Others

Order Date: December 2, 2025

Bench: Justice Arun Kumar Singh Deshwal