In Patna High Court through Learned Registrar General vs. The State of Bihar through Collector-cum-D.M., Begusarai Sri Tushar Singla, District Begusarai & Ors. (2025), Patna High Court's Division Bench of Justices Bibek Chaudhuri and Dr. Anshuman delivered a 19-page long judgement dated December 16, 2025, adjudicated a Miscellaneous Jurisdiction Case registered suo motu by the High Court through its Registrar General against the State of Bihar, arising out of non-compliance with a compensation award passed by the Motor Accident Claims Tribunal, Begusarai, and subsequent developments in the execution proceedings before the Civil Court of competent jurisdiction.

By a judgment and award, dated August 18, 2023 in a Claim Case, the Motor Accident Claims Tribunal, Begusarai awarded a sum of Rs. 11,61,318/- along with interest at the rate of 6% per annum from the date of giling of the claim petition till realization, in favour of the claimants, who are the legal heirs of the deceased Nutan Devi, a mother of four children. The deceased had succumbed to injuries sustained in a motor accident caused by rash and negligent driving of a police vehicle owned by the Bihar Police Department. The liability to pay the compensation was gastened vicariously on the State of Bihar, and the Tribunal specifically directed the District Magistrate, Begusarai and the Superintendent of Police, Begusarai to ensure payment within one month from the date of the award.

Despite this direction, the awarded amount was not disbursed to the claimants. Consequently, the vlaimants filed Execution Case No. 01 of 2024 before the Court of District & Additional Sessions Judge-III-cum-Special Judge (MACT), Begusarai. In the execution proceedings, multiple orders were passed directing compliance, but the amount remained unpaid on the ground of non-allotment of funds by the State authorities.

On July 10, 2025, the Executing Court sought explanations from the District Magistrate, Begusarai and the Superintendent of Police, Begusarai regarding their failure to adhere to the previous orders.

On July 25, 2025, noting the absence of any response, the Executing Court resolved to report the matter to the High Court for initiation of contempt proceedings against the concerned officers.

On August 21, 2025, the Executing Court extended a final opportunity of one month for payment, observing that non-compliance would render the officers liable for contempt of Court.

On September 23, 2025, the Executing Court recorded that the Superintendent of Police, Begusarai had conveyed to the Principal District & Sessions Judge, Begusarai n his chamber that no adverse order should be passed against him, as he was very Powerful and even this Court could not take any action against him. It was further recorded that the learned District Judge advised the Superintendent of Police that he would have a

cake-walk in this Court in the event of any contempt proceedings. The learned Executing Court expressed its

objection to such interference in the performance of its

judicial duties.

On September 24, 2025, a letter dated the previous day from the Superintendent of Police to the Deputy Inspector General, Begusarai seeking allocation of funds was placed before the Executing Court. However, observing the casual attitude of the authorities, the Court refused to grant any further extension.

On October 14, 2025, the learned Executing Court, treating the conduct of the District Magistrate and the Superintendent of Police as contemptuous, directed them to file show-cause affidavits and registered a separate miscellaneous case recommending contempt proceedings.

On October 29, 2025, the Superintendent of Police filed a response, reserving his right to submit a detailed reply before the High Court.

On November 7, 2025, the Government Pleader submitted on behalf of the State that payment would be made within the next ten days, as the officers were engaged in the legislative assembly election duties. The  Executing Court fixed November 17, 2025 as the final date for compliance, failing which the matter would be forwarded to this Court.

On November 17, 2025, noting that no payment had been made and no show-cause affidavits were filed, the Executing Court directed transmission of the extracts of the miscellaneous case to the Registrar General of this Court with a recommendation to initiate contempt proceedings against the District Magistrate and the Superintendent of Police. On the same date, the Executing Court also noted that by an order dated November 15, 2025, the learned District Judge had recalled the execution case to his own file for hearing and disposal.

The Executing Court recorded its view that the order was passed hastily without examining the records and appeared to be aimed at shielding the officers from contempt proceedings. It further expressed that the morale of subordinate judicial officers had been affected, and that orders of the subordinate judiciary seemed non-binding on executive authorities. The Executing Court handed over the case records to the learned District Judge as directed.

13. Subsequently, by a letter dated 26.11.2025 sddressed to the Registrar General of this Court, the District Judge placed his version of the facts. He stated that the District Magistrate and the Superintendent of Police had informed him that steps for allotment of funds were underway, and the matter had been discussed repeatedly in District Level Monitoring Committee (DLMC) meetings. The District Judge mentioned that he had apprised the Executing Court of these discussions. He further stated that certain comments made by the Executing Court were uncalled for and could jeopardize relations between the judiciary and the executive. Upon receipt of a letter dated 15.11.2025 from the Superintendent of Police enclosing various orders of the Executing Court, and after considering the discussions in DLMC meetings, the learned District Judge exercised powers under Section 24 of the Code of Civil Procedure, 1908 to withdraw the execution case from the learned Executing Court and transfer it to his own file for trial and disposal. The District Judge noted that after receiving this order on November 16, 2025, the learned Executing Court passed orders forwarding the record to this Court and making remarks against him. Accordingly, the District Judge requested the High Court to take cognizance of these facts and take appropriate action.

Upon receipt of the references both from the Executing Court (through Court records and recommendation dated November 17, 2025) and from the District Judge (letter dated November 26, 2025), the  the Chief Justice was pleased to direct the Registry to register the matter ss a suo motu contempt reference, being Miscellaneous Jurisdiction Case.

15. Thus, the matter is now before this Court for consideration.

Since on the date of admission, nobody appeared on behalf of the petitioner, we propose to appoint Mr. Sanjay Singh, learned Sr. Advocate as an amicus curiae in the instant case to assist this Court.

17. Mr. Singh graciously consented and copy of the brief was served upon him. 

It was submitted by the amicus curiae that the order passed by the Motor Accident Claims Tribunal, Begusarai was within the jurisdiction of the Tribunal. The said order granting compensation to the petitioners reached its finality. The State of Bihar or the Opposite Parties did not file any appeal against the said order. At the same time, indisputably, the order, directing the Superintendent of Police, Begusarai and the Collector-cum-District Magistrate, Begusarai to pay compensation to the petitioners on account 

Sri Tushar Singla, Collector-cum-D.M., Begusarai District Begusarai

Sri Maneesh S.P. Begusarai, District Begusarai