Introduction
In a significant order pronounced on 16th February 2026, the High Court of Madhya Pradesh, Indore Bench, delivered a strong ruling in Contempt Petition Civil No. 771 of 2025 (Vivek Singh Chouhan v. Govind Mohan), holding the Union of India prima facie guilty of contempt for willfully disobeying a court order directing conferral of the President’s Gallantry Medal upon a decorated police officer.
The matter was heard before Hon’ble Justice Pranay Verma wherein the Court found that the respondent/Union of India had acted in a mischievous and unwarranted manner by attempting to substitute a lesser award in place of the one specifically directed by the Court.
Background of the Case
The petitioner, Shri Vivek Singh Chouhan, was serving as Incharge SHO, Police Station Ghatigaon, District Gwalior in the year 2003. On 24th June 2003, acting on intelligence input about the presence of dacoits in village Dadakheda, he led a police party to the spot. In the operation that followed, two dacoits were neutralized, two twelve-bore rifles and several cartridges were seized, and the petitioner himself sustained injuries during the encounter.
A subsequent magisterial enquiry gave the petitioner a clean chit, and the Superintendent of Police recommended him for both out-of-turn promotion and the President’s Police Medal for Gallantry. Despite the recommendation, no action was taken by the authorities for years.
The petitioner was compelled to approach the High Court of Madhya Pradesh by filing W.P. No. 15215/2013, which was allowed on 02.04.2018, directing the State Government to forward his case to the concerned authority for the President’s Medal for Gallantry Award within 60 days.
The State complied by forwarding the name on 01.04.2019. However, the Ministry of Home Affairs (Under Secretary, PMA) rejected the claim on 14.10.2019. This led to the filing of a fresh W.P. No. 10038/2024, which was again allowed by the High Court on 09.12.2024, directing the Union of India to ensure the petitioner receives the Gallantry Award within one month. This order was further affirmed by the Division Bench on 09.01.2025 in W.A. No. 3192/2024.
The Contempt Petition
Despite two successive orders of the High Court spanning over a decade of litigation, the Union of India failed to confer the President’s Gallantry Medal upon the petitioner. Instead, in its compliance report, the government submitted that the Hon’ble President of India had approved the Gallantry Medal (GM) — a categorically different and significantly lesser award — as compliance with the court’s direction.
This triggered Contempt Petition Civil No. 771 of 2025.
Key Arguments Advanced on Behalf of the Petitioner
The following arguments were advanced before the Court on behalf of the petitioner:
First, the respondent’s act of conferring a Gallantry Medal (GM) in place of the President’s Gallantry Medal was a deliberate and mischievous misinterpretation of the court’s order, designed to nullify its effect without technically appearing non-compliant.
Second, the entire history of litigation from 2003 onwards had been centered exclusively around the President’s Gallantry Medal. The petitioner had never claimed any other award, and every order of the court had been passed in the context of that specific medal alone.
Third, the President’s Gallantry Medal and the Gallantry Medal (GM) are entirely distinct awards. The President’s Gallantry Medal is the highest gallantry award conferred upon police personnel and is awarded to only one person, whereas the Gallantry Medal (GM) is a general award given simultaneously to numerous persons.
Fourth, the mere use of the words “gallantry award” in the last line of the court’s order could not be construed to permit the government to confer a lesser award, especially when the prayer in the writ petition, the entire proceedings, and all previous orders were explicitly and exclusively in respect of the President’s Gallantry Medal.
Fifth, the respondent’s attempt to create ambiguity in a clear order of the court was an effort to overreach the lawful authority of the court and was wholly illegal.
The Court’s Finding
Hon’ble Justice Pranay Verma accepted the arguments advanced on behalf of the petitioner and made the following significant observations:
The Court held that the respondent had acted in an “absolutely mischievous and unwarranted manner” by approving the Gallantry Medal (GM) in purported compliance of an order that was clearly and unambiguously directed towards the President’s Gallantry Medal. The Court further observed that the respondent had “clearly overreached the order” and had “willfully and deliberately disobeyed and disregarded” the directions of the Court.
The Court found the respondent prima facie guilty of contempt of the lawful authority of the High Court of Madhya Pradesh. However, exercising judicial restraint, the Court granted one final opportunity to the Union of India to comply with the original order before the next date of hearing. The Court clearly directed that if compliance is not ensured, the respondent shall automatically be deemed guilty of contempt and further proceedings in accordance with law shall be initiated.
The matter has been listed for hearing in the week commencing 23rd March 2026.
Why This Judgment Matters
This order is significant for several important reasons.
For police personnel and government employees, it reaffirms that courts will not permit authorities to use technical or linguistic ambiguity in orders to dilute the substance of judicial directions. The spirit and intent of an order, read in the context of the entire proceedings, shall always prevail.
For contempt law jurisprudence, the judgment underscores the well-settled principle that in contempt proceedings, the only relevant question is whether the court’s order has been complied with in letter and spirit — not whether the party had the merit to receive the benefit in the first place.
For citizens fighting bureaucratic delays, this case spanning over two decades is a testament to the fact that perseverance in legal proceedings can ultimately deliver justice even against the might of the Union of India. The judiciary remains a steadfast guardian of the rights of individuals against institutional apathy and deliberate non-compliance.
Conclusion
The High Court of Madhya Pradesh’s order in Contempt Petition No. 771 of 2025 is a powerful reminder that judicial orders must be complied with in their true spirit. Attempts by state and central authorities to circumvent court directions through creative interpretations will not be tolerated. The Court’s ruling reaffirms that the intent and history of litigation shall always be the guiding light in interpreting judicial orders, and that the rights of citizens — including those who serve the nation with bravery — shall be protected by the courts of law.
