Delhi High Court Refuses Contempt Against PNB Over Trust Bank Accounts; Finds Conflicting Interpretations of Earlier Order Prevent Attribution of Wilful Disobedience to Bank
Delhi High Court Refuses to Blame PNB Amid Competing Instructions Over Trust Accounts; Disposes Contempt Plea and Leaves Signatory Issue for Adjudication
Facts
The Ch. Aishi Ram Batra Public Charitable Trust (Regd.) filed a contempt petition before the Delhi High Court seeking initiation of proceedings against Punjab National Bank (PNB) for alleged wilful disobedience and non-compliance with an order dated 29 May 2026 passed in pending civil proceedings, CS(OS) 303/2026.
By the order dated 29 May 2026, the Roster Bench had directed that the banks would comply with the Minutes of Meetings of the Governing Body dated 20 December 2025 and 22 December 2025. Interim orders were directed to continue.
The controversy concerned the manner in which the Trust/Hospital’s bank accounts with PNB were to be operated and, specifically, who constituted the authorised signatories for cheques and payment instruments.
According to the petitioner, the Governing Body resolutions, read with the KYC documents, provided a clear banking mandate requiring signatures of any two members from Group A together with one member from Group B.
Respondent No. 4, Jai Batra, however, disputed this interpretation and had written to PNB on 1 June 2026, requesting withholding of cheque encashment and other banking activities based upon his understanding of the High Court’s 29 May order.
This resulted in competing instructions being placed before PNB and ultimately led to the contempt petition.
Issues
The principal issues before the High Court were:
- Whether PNB had wilfully disobeyed the order dated 29 May 2026 by failing to operate the Trust/Hospital’s accounts according to the petitioner’s interpretation of the Governing Body resolutions;
- Whether the order dated 29 May 2026 prescribed a sufficiently clear and unambiguous banking mandate capable of supporting contempt proceedings;
- Whether PNB could be faulted when it had received conflicting communications and instructions from rival sides;
- Whether the dispute concerning the identity and combination of authorised signatories could properly be determined in contempt jurisdiction;
- Whether the KYC form supported the petitioner’s interpretation of the Governing Body resolutions;
- What effect should be given to the subsequent Vacation Bench order dated 10 June 2026, which directed PNB to resume normal banking operations;
- Whether the Vacation Bench’s interpretation of the 29 May order was consistent with what the Roster Bench had originally intended; and
- Whether these questions should instead be determined by the Roster Bench in the pending substantive proceedings.
Petitioner’s Arguments
The Trust argued that the order dated 29 May 2026 contained a categorical direction requiring PNB to comply with the Governing Body Minutes dated 20 and 22 December 2025.
According to the petitioner, a KYC form had already been filed with PNB and therefore there could be no genuine ambiguity regarding the persons authorised to operate the accounts.
The petitioner contended that, when the Governing Body resolutions were read with the KYC mandate, cheques were required to bear signatures of:
- any two authorised members from Group A; and
- one member from Group B.
Accordingly, PNB was allegedly bound to honour banking instruments satisfying this mandate.
The petitioner maintained that failure to do so constituted non-compliance with the High Court’s express order and justified contempt proceedings.
Respondents’ Arguments
Respondent No. 4, Jai Batra, disputed the petitioner’s interpretation of the Governing Body resolutions.
His position was that the mandate recorded in the Minutes did not refer to the alleged requirement that cheques could be signed by any authorised members falling within Group A and Group B.
It was further submitted that his email dated 1 June 2026 asking PNB to withhold cheque encashment and banking activities was itself based upon his understanding of the High Court’s 29 May 2026 order.
Thus, PNB had received competing interpretations and instructions from the rival sides.
Respondent No. 4 also contended that the Vacation Bench, through its subsequent order dated 10 June 2026, could not have issued directions going beyond the scope of the original Roster Bench order dated 29 May 2026.
Analysis of the Law
Wilful Disobedience Required for Contempt
The contempt petition specifically sought action against PNB for wilful disobedience and non-compliance with the High Court’s earlier order.
The decisive question therefore became whether PNB’s conduct could properly be characterised as culpable disobedience when the very meaning and operational effect of the earlier order remained disputed.
Although the judgment does not undertake an elaborate exposition of contempt jurisprudence or cite precedents on this point, its application reflects the requirement that culpability cannot readily be attributed where the underlying direction is subject to genuine competing interpretations.
Rival Parties Interpreted the Order Differently
The Court expressly recorded that the order dated 29 May 2026 was being:
“interpreted by both the parties in a divergent and conflicted manner.”
This became central to the outcome.
The petitioner believed that the order required PNB to implement the banking mandate according to the Group A/Group B signatory arrangement.
Respondent No. 4 interpreted the same material differently.
The Court was also informed that applications concerning the injunction and interpretation of the 29 May 2026 order were themselves pending adjudication before the Roster Bench.
PNB Could Not Be Faulted for Its Conduct
Given that PNB had received letters from both sides asserting conflicting interpretations, the Court held:
“the respondent-PNB, in receipt of letters from both the sides, cannot be faulted for its action.”
The Court further held that while the actual interpretation of the earlier order and the consequential mandate governing PNB remained pending before the Roster Bench, no culpability could be attributed to PNB for the manner in which it acted.
This was effectively fatal to the contempt case.
Minutes and KYC Form Were Not Identical
The Court identified another material difficulty in the petitioner’s case.
While the relevant Minutes stipulated that the authorised signatures would be those of three representatives—Hemant Batra, Jai Batra and Sushil Kumar Batra—the KYC form did not contain the same stipulation.
This reinforced the existence of a substantive dispute concerning the actual banking mandate.
The Court therefore declined to resolve the authorised-signatory controversy within contempt proceedings.
Roster Bench Must Decide Authorised Signatory Dispute
The Court found that there remained an unresolved dispute between the parties concerning the authorised signatories.
Since that issue was already pending before the Roster Bench, the Court held that the final determination of the Roster Bench should be awaited.
The contempt jurisdiction was therefore not used as a vehicle to conclusively interpret the substantive interim directions in the pending suit.
Effect of Vacation Bench Order
An important further development was the Vacation Bench’s order dated 10 June 2026.
As reproduced on page 7 of the judgment, the Vacation Bench directed PNB to:
- resume normal banking operations; and
- honour all cheques/payment instruments strictly in terms of the Resolution dated 22 December 2025 and the existing operational mandate.
That mandate was expressly described as requiring any two signatories from Group A together with the mandatory signature of the Finance Controller from Group B.
The Court subsequently summarised the same direction, recording that PNB was required to resume normal banking operations and continue the Group A/Group B operational mandate.
Whether Vacation Bench Went Beyond Earlier Order Left Open
Respondent No. 4 argued that the Vacation Bench could not have issued directions extending beyond what the Roster Bench had originally directed on 29 May 2026.
Justice Mini Pushkarna did not decide that controversy.
Instead, the Court directed that the question whether the Vacation Bench’s interpretation/direction was consistent with the Roster Bench’s intention should also be raised before and determined by the Roster Bench.
Precedent Analysis
The judgment does not cite or analyse any judicial precedents on civil contempt.
Instead, Justice Mini Pushkarna disposed of the matter principally upon the factual and procedural circumstances surrounding:
- the order dated 29 May 2026;
- the Governing Body Minutes dated 20 and 22 December 2025;
- the KYC mandate;
- competing communications sent to PNB;
- the pending applications before the Roster Bench; and
- the Vacation Bench’s subsequent order dated 10 June 2026.
Accordingly, the principal value of the judgment lies in its application of contempt principles to an ambiguous or disputed underlying direction, rather than formulation of a new doctrinal rule through precedent.
The decision demonstrates that where rival parties genuinely interpret an earlier judicial direction differently and the proper interpretation itself remains pending before the substantive Bench, a third party acting amidst those conflicting instructions may not readily be held culpable for wilful disobedience.
Court’s Reasoning
The High Court’s reasoning rested primarily upon the absence of clear culpability attributable to PNB.
The original order required PNB to comply with certain Governing Body Minutes. However, those Minutes, the KYC documents and the subsequent communications were being interpreted differently by the competing sides.
The Court considered it particularly important that the very interpretation of the 29 May order remained pending before the Roster Bench.
In those circumstances, PNB had effectively been placed between competing instructions from rival parties.
The Court therefore found that the bank “cannot be faulted” and that no culpability could be attributed to it for the manner in which it had acted.
The Court similarly declined to decide whether the Vacation Bench’s 10 June order correctly interpreted or expanded upon the Roster Bench’s 29 May order.
That question, too, was left for determination by the Roster Bench.
Thus, rather than using contempt jurisdiction to resolve the underlying substantive banking dispute, the Court left those questions to the Bench already seized of the suit and disposed of the contempt proceedings.
Conclusion
The Delhi High Court disposed of the contempt petition against Punjab National Bank without attributing any culpability to the bank.
The Court held that:
- the 29 May 2026 order was being interpreted differently by the rival parties;
- PNB had received competing communications from both sides;
- the authorised-signatory dispute remained pending before the Roster Bench;
- the Governing Body Minutes and KYC documentation did not eliminate the dispute;
- PNB therefore could not be faulted for the manner in which it acted;
- the proper interpretation of the 29 May order should be determined by the Roster Bench; and
- the question whether the Vacation Bench’s 10 June directions were consistent with the Roster Bench’s original intention should likewise be raised before that Bench.
The contempt petition and all pending applications were accordingly disposed of. All interim directions merged into the final order, and the next date of 11 September 2026 was cancelled.
Case Details
Case: Ch. Aishi Ram Batra Public Charitable Trust (Regd.) v. Punjab National Bank & Ors.
Court: High Court of Delhi at New Delhi
Case Number: CONT.CAS(C) 1043/2026 & CM APPLs. 38705/2026, 38706/2026 & 38816/2026; CNR No. DLHC010260092026
Judge: Justice Mini Pushkarna
Date: 12 August 2026
Result: Contempt petition disposed of; no culpability attributed to PNB; dispute over interpretation of banking mandate and authorised signatories left for determination by the Roster Bench.
