A contempt tribunal cannot sit in appeal over a reasoned order complying with its direction.

The Land Reforms and Tenancy Tribunal had directed the B.L. & L.R.O., Jagatballavpur, to consider the respondents’ representation in accordance with law.

The B.L. & L.R.O. subsequently disposed of the representation by a reasoned order dated October 17, 2025, addressing the application of Sections 4, 5 and 6 of the West Bengal Estate Acquisition Act, 1953.

In contempt proceedings, the Tribunal held that the representation had not been properly disposed of and directed the B.L. & L.R.O. to accept a fresh Form B and take steps to reflect the respondents’ claimed entitlement under Section 6(5).

The State challenged that order before the High Court.

1. Whether the Tribunal, exercising contempt jurisdiction, could re-examine the merits of a reasoned order passed in compliance with its direction to consider a representation in accordance with law.

2. Whether the Tribunal could direct the B.L. & L.R.O. to accept a fresh Form B and give effect to the respondents’ claimed statutory entitlement in those contempt proceedings.

A direction to consider a representation “in accordance with law” requires the authority to consider and decide it; it does not authorise the contempt forum to review the legality or merits of the resulting decision. A reasoned decision made in purported compliance may be challenged before the forum designated by law, but any doubt about its legal correctness does not, by itself, fall within contempt jurisdiction.

Section 6 of the West Bengal Estate Acquisition Act, 1953, including its non-obstante provision and Section 6(5), concerns retention of land in specified circumstances; the merits of the B.L. & L.R.O.’s application of those provisions were not determined in this writ petition.

The Tribunal’s original direction was limited to deciding the respondents’ representation in accordance with law and did not determine its merits.

The B.L. & L.R.O. considered the relevant legal framework and issued a reasoned order, thereby complying with that direction.

Whether that order correctly interpreted the 1953 Act was a matter for challenge before the appropriate forum, not for determination through contempt proceedings.

By directing acceptance of a fresh Form B and recognition of the claimed entitlement, the Tribunal effectively reconsidered the representation and sat in appeal over the B.L. & L.R.O.’s decision, exceeding its contempt jurisdiction.

It clarified that the respondents remained free to challenge the B.L. & L.R.O.’s order dated October 17, 2025, before the appropriate forum, which would decide any such challenge independently and on its merits.

No order as to costs was made.