A second contempt petition is not maintainable on the same cause of action once compliance is recorded.

The Petitioner filed a second Contempt Petition (CP) alleging willful disobedience of the Tribunal’s order dated 11.07.2022 in OA No. 1363/2022, which had directed the respondents to pass a reasoned order on his representation

The Petitioner had previously filed CP No. 112/2024 on the same cause of action, which was closed on 07.07.2024 after the Tribunal found compliance through the respondents' order dated 20.10.2022

Despite being granted liberty to challenge the compliance order in fresh proceedings, the Petitioner filed this second CP, arguing it was maintainable and that the respondents had not taken "required action"

1. Whether a second contempt petition is maintainable on the same/identical cause of action after a previous contempt petition has been adjudicated and closed

2. Whether the acts of the respondents constituted "willful disobedience" under the Contempt of Courts Act when an order of compliance had already been passed

The Tribunal applied the principle that contempt is a matter between the Court and the contemnor, and once compliance is made, its correctness cannot be examined under contempt jurisdiction, as established in Ram Prasad Gupta v. Avinash Dikshit

It relied on B.D. Tiwari v. Alok Tandon and J.S. Parihar v. Ganpat Duggar, which held that a contempt court cannot sit in appeal or examine the merits of a resultant order passed by statutory authorities

Furthermore, relying on Anil Kumar Sahi (2) v. Prof Ram Sewak Yadav, the court noted that a mere error of judgment or lack of intended results does not constitute "willful disobedience" if best efforts were made to comply

The Tribunal distinguished the precedents cited by the Petitioner, specifically S.K. Srivastava v. Ms. X, noting that the present case lacked the "repeated and deliberate defiance" or "contumacious conduct" required to justify a second contempt proceeding

The Tribunal reasoned that since it had already recorded compliance in the first CP (No. 112/2024) and dismissed it, the matter was settled within the contempt jurisdiction

The court emphasized that the Petitioner's dissatisfaction with the nature or quality of the compliance order does not grant a right to file successive contempt petitions; instead, any grievance regarding the legality of the compliance order gives rise to a fresh cause of action to be challenged through appropriate legal forums, not via the contempt route

The Petition was dismissed

The Tribunal reiterated that contempt jurisdiction cannot be invoked repeatedly on the same cause of action

liberty was granted to the Petitioner to avail appropriate legal remedies to challenge the compliance order in accordance with the law