The Delhi High Court disposed of a contempt petition alleging non-compliance with a Family Court visitation order by directing structured group activities between the father and his twin children during monthly supervised visits, emphasizing the need to build a natural bond while maintaining decorum between estranged parents.
Background & Facts
The Dispute
The petitioner, Samrat Singh Rawat, filed a contempt petition under CONT.CAS(C) 1353/2026 before the High Court of Delhi alleging willful disobedience of an order dated 06th June, 2026 passed by the Family Court-02, South-East, Saket, New Delhi in GP 18/2020. The Family Court had granted the petitioner visitation rights with his twin children (a boy and a girl) during summer vacations on three days, from 11:00 AM to 01:00 PM at the Children's Room, Family Court, Saket. The petitioner contended that these visitations were of brief duration and were not conducted properly.
Key Facts
- The parties are estranged parents of twin children (a boy and a girl) who have been living with the respondent-mother since childhood
- The Family Court order dated 06th June, 2026 in GP 18/2020 granted summer vacation visitation to the petitioner-father on three days, 11:00 AM to 01:00 PM at the Children's Room, Family Court, Saket
- An existing visitation schedule was already in place: the petitioner and his father were granted visitation once a month, every third Saturday from 11:00 AM to 02:00 PM at the Children's Room, Family Court, Saket
- The petitioner's counsel submitted that the respondent-mother's presence inside the Children's Room during visitation prevented the children from freely mixing with the petitioner-father
- The petitioner sought unsupervised visitation with the children
- The respondent's counsel, on instructions, submitted that even if the respondent-mother tried to come out of the Children's Room, the children ran after her, indicating their primary attachment to the mother
- The summer vacations had already concluded by the time of the hearing before the High Court
- The third Saturday of August 2026 (15th August) was a national holiday, due to which the scheduled monthly visitation could not take place
Procedural History
- 06.06.2026: Family Court-02, South-East, Saket passed order in GP 18/2020 granting summer vacation visitation rights to petitioner
- 17.08.2026: Contempt petition CONT.CAS(C) 1353/2026 heard and disposed of by the High Court of Delhi
- 22.08.2026: Make-up visitation directed for the missed session of 15.08.2026
Relief Sought
The petitioner sought enforcement of the Family Court's visitation order dated 06.06.2026, alleging non-compliance during summer vacations, and prayed for unsupervised visitation rights with the twin children.
The Legal Issue
The central questions were: (1) whether the respondent-mother willfully disobeyed the Family Court's visitation order dated 06.06.2026 during summer vacations; (2) whether the petitioner-father was entitled to unsupervised visitation given the children's primary attachment to the mother; and (3) what directions would serve the best interests of the twin children in fostering a meaningful relationship with their father.
Arguments Presented
For the Petitioner
Mr. Jaspreet Singh, counsel for the petitioner, submitted that the visitations granted during summer vacations were only for brief durations and were not held properly in terms of the Family Court order. He further argued that the respondent-mother's continued presence inside the Children's Room during the monthly visitation sessions inhibited the twin children from freely interacting with the petitioner-father, and therefore the petitioner ought to be granted unsupervised visitation to facilitate a natural parent-child bond.
For the Respondent
Mr. Prabhjit Jauhar, Ms. Shambhavi and Ms. Sehaj Kataria, counsel for the respondent, submitted on instructions that the children had been living with the respondent-mother since childhood and exhibited a strong primary attachment to her. They contended that even if the respondent-mother attempted to step out of the Children's Room during visitation, the children would run after her, making unsupervised visitation impractical and potentially distressing for the children at this stage.
The Court's Analysis
The Court, presided over by Hon'ble Ms. Justice Mini Pushkarna, noted at the outset that the summer vacations were already over, rendering the specific prayer for enforcement of summer visitation moot. The Court observed that a monthly visitation schedule was already operational - every third Saturday from 11:00 AM to 02:00 PM at the Children's Room, Family Court, Saket - which included the petitioner and his father.
Addressing the core concern of the petitioner regarding the mother's presence inhibiting bonding, the Court recorded the submission that the twin children did not freely mix with the father when the mother was present in the Children's Room. However, the respondent's submission that the children ran after the mother even when she attempted to leave indicated the children's deep-rooted attachment and possible anxiety in her absence.
Rather than ordering unsupervised visitation - which the Court implicitly found premature given the children's age and attachment patterns - the Court crafted a graduated, child-centric approach to foster the father-child bond within the existing supervised framework. The Court directed that during visitation hours, the petitioner and respondent shall engage in group activities with the twin children, including playing board games and other games. This structured interaction was designed to create a natural, low-pressure environment for bonding.
The Court further directed that the petitioner would be at liberty to show photographs of other members of his family to the children so that the children recognize the other members of the family of the father also. Additionally, the petitioner would be at liberty to click photographs with the children, if the children are so comfortable, with a direction to the petitioner to develop the comfort level with the children.
Recognizing that parental conflict during visitation harms children, the Court explicitly directed both parties to cooperate with each other in respect of the group activities, not engage in any untoward conversation, maintain decorum and civilized behavior in front of the children, and refrain from making any personal remarks against each other.
Regarding the missed visitation on 15th August 2026 (third Saturday, a national holiday), the Court directed the respondent to bring the minor children to the Children's Room at Family Court, Saket between 11:00 AM to 02:00 PM on 22nd August, 2026 (the next Saturday) in lieu of the missed session. The Family Court, Saket was directed to ensure that the Child Counselor shall be present on 22nd August, 2026 at the time of visitation, in terms of orders already passed by the Family Court.
"Accordingly, in order that the children build a bond with the father, it is directed that the petitioner and respondent shall engage in group activities with the twin children, including, playing board games and other games. Further, the petitioner would also be at liberty to show photographs of other members of his family to the children so that the children recognize the other members of the family of the father also."
The Verdict
The contempt petition was disposed of with the following operative directions: (1) The petitioner and respondent shall engage in group activities (board games, other games) with the twin children during the petitioner's monthly visitation hours; (2) The petitioner may show photographs of his family members to the children; (3) The petitioner may click photographs with the children if they are comfortable; (4) Both parties shall cooperate, maintain decorum, avoid untoward conversation, and refrain from personal remarks during visitation; (5) The respondent shall bring the children for a make-up visitation on 22nd August, 2026 (Saturday) from 11:00 AM to 02:00 PM at the Children's Room, Family Court, Saket, in lieu of the missed 15th August session; (6) The Family Court, Saket shall ensure the Child Counselor's presence on 22nd August 2026; (7) A copy of the order shall be sent to the Children's Room, Family Court, Saket forthwith.
What This Means For Similar Cases
Supervised Visitation Can Be Structured To Foster Bonding
Courts are moving beyond passive supervision toward active, structured engagement during visitation. The direction to conduct group activities (board games, shared play) and share family photographs transforms supervised visitation from a mere access mechanism into a therapeutic intervention. Practitioners should advocate for specific, age-appropriate activity directions in visitation orders rather than leaving interaction unstructured.
Parental Decorum Is Enforceable, Not Aspirational
The Court's explicit direction that parties "shall not engage in any untoward conversation... shall maintain decorum and civilized behavior... and refrain from making any personal remarks" elevates behavioral standards from hortatory to mandatory and enforceable. Lawyers should seek similar specific conduct restraints in interim orders to protect children from parental conflict during handovers and visits.
Graduated Transition From Supervised To Unsupervised Access
The judgment illustrates a calibrated approach: where children show primary attachment to one parent and anxiety on separation, courts will not order unsupervised visitation immediately but will design intermediate steps (group activities, photo sharing, counselor presence) to build comfort. Practitioners representing non-custodial parents should frame prayers for expanded access as a phased process with measurable milestones, not a binary demand.
Make-Up Visitation For Missed Sessions Is Standard Practice
The direction for a make-up session on the next available Saturday (22.08.2026) for the holiday-missed visit (15.08.2026) confirms that visitation rights are substantive entitlements, not discretionary favors. Lawyers should routinely include make-up provisions in consent orders and seek specific enforcement when sessions are missed for any reason.
Child Counselor Presence Adds Professional Oversight
The Court's insistence on Child Counselor presence during the make-up visitation signals that professional monitoring is integral to high-conflict supervised access. Practitioners should ensure Family Court orders explicitly mandate counselor availability for all sessions, not just initial ones, and seek contempt if the facility fails to provide one.
