IN RE: PATANJALI AYURVED LIMITED THROUGH ITS MANAGING DIRECTOR, ACHARYA BALKRISHNA AND BABA RAMDEV IN THE MATTER OF:INDIAN MEDICAL ASSOCIATION AND ANR versus UNION OF INDIA AND OTHERS

IN RE: PATANJALI AYURVED LIMITED THROUGH ITS MANAGING DIRECTOR, ACHARYA BALKRISHNA AND BABA RAMDEV IN THE MATTER OF:INDIAN MEDICAL ASSOCIATION AND ANR versus UNION OF INDIA AND OTHERS

The Court found that the proposed contemnors (Patanjali, Acharya Balkrishna and Baba Ramdev) had, in the immediate aftermath of an undertaking recorded on 21.11.2023, made public statements and published advertisements asserting cures for ailments listed in the DMR Act/Rules, thus prima facie breaching the undertaking and statutory prohibitions; a conditional apology was rejected, but after the contemnors tendered unconditional apologies, published prominent apologies in newspapers and took remedial steps (including withdrawal of certain advertisements and suspension-related measures), the Court accepted the subsequent unconditional apologies, discharged the contempt notices and closed...

Parties
Petitioner: Indian Medical Association; Proposed Contemnor / Respondent No.5: Patanjali Ayurved Limited; Managing Director; Proposed Contemnor / Respondent No.6: Acharya Balkrishna; Proposed Contemnor / Respondent No.7: Baba Ramdev; Respondent: Union of India
Jurisdiction
India
Judgment Date
13 August 2024
Procedural Posture
Suo Motu Contempt Petition (civil) No. 4 of 2024; Writ Petition (civil) No. 645 of 2022 / Order Disposing Suo Motu Contempt Proceedings (judgment Dated 13 August 2024)
Outcome
Proposed contemnors' unconditional apologies accepted; contempt notices discharged; contempt proceedings closed; proposed contemnors cautioned to strictly abide by undertakings
Legal Topics
Contempt, Civil Contempt, Breach of Undertaking, Wilful Disobedience, Misleading Advertisements, Apology (qualified Vs Unconditional)
Contempt of Courts Act, 1971 Constitution of India Drugs and Magic Remedies (objectionable Advertisement) Act, 1954 Drugs and Magic Remedies (objectionable Advertisement) Rules, 1955 Contempt Civil Contempt Breach of Undertaking Wilful Disobedience +2 more

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Parties

Indian Medical Association

Petitioner

Patanjali Ayurved Limited

Proposed Contemnor / Respondent No.5

Acharya Balkrishna

Managing Director; Proposed Contemnor / Respondent No.6

Baba Ramdev

Proposed Contemnor / Respondent No.7

Union of India

Respondent

Procedural Posture

Suo Motu Contempt Petition (civil) No. 4 of 2024; Writ Petition (civil) No. 645 of 2022 / Order Disposing Suo Motu Contempt Proceedings (judgment Dated 13 August 2024)

Legal Issues

  1. 1 Whether Patanjali and its principals wilfully breached the undertaking given to the Court on 21.11.2023 by holding a press conference on 22.11.2023 and by publishing advertisements claiming cures prohibited by the DMR Act/Rules
  2. 2 Whether statements and advertisements describing products as a "permanent solution" for ailments listed in the Schedules to the DMR Act/Rules amounted to contempt
  3. 3 Whether the apologies tendered were unconditional, bona fide and sufficient to purge contempt and warrant closure of proceedings

Ratio Decidendi

The Court found that the proposed contemnors (Patanjali, Acharya Balkrishna and Baba Ramdev) had, in the immediate aftermath of an undertaking recorded on 21.11.2023, made public statements and published advertisements asserting cures for ailments listed in the DMR Act/Rules, thus prima facie breaching the undertaking and statutory prohibitions; a conditional apology was rejected, but after the contemnors tendered unconditional apologies, published prominent apologies in newspapers and took remedial steps (including withdrawal of certain advertisements and suspension-related measures), the Court accepted the subsequent unconditional apologies, discharged the contempt notices and closed...

Court Disposition

Proposed contemnors' unconditional apologies accepted; contempt notices discharged; contempt proceedings closed; proposed contemnors cautioned to strictly abide by undertakings

Orders

  • Unconditional apologies tendered by Patanjali, Acharya Balkrishna and Baba Ramdev accepted
  • Contempt notices issued to the proposed contemnors discharged