Admitted compliance may render contempt proceedings unnecessary without determining willful disobedience.

Devendra Prasad Singh, a former Assistant Postmaster, filed a contempt petition alleging non-compliance with the Tribunal’s order in O.A. No. 050/932/2015.

At the hearing, the applicant’s counsel stated that the directions had been complied with, and counsel for the respondents confirmed compliance.

The Tribunal recorded that it would not determine whether contempt had occurred or whether any alleged contemnor was guilty or exonerated.

It also considered Rule 6 of the CAT (Contempt of Courts) Rules, 1992, which ordinarily requires contempt proceedings to be dealt with by a Bench of at least two Members.

Whether the contempt petition should be closed after both sides confirmed that the underlying order had been complied with.

Whether the Tribunal could end the proceedings without referring the matter to a two-Member Bench under Rule 6, where it made no finding on contempt and issued no coercive direction.

The Tribunal described contempt jurisdiction as concerned with securing compliance with its orders and examining whether there has been wilful disobedience; it also referred to section 27 of the Administrative Tribunals Act in connection with securing compliance.

Rule 6 of the CAT (Contempt of Courts) Rules, 1992, as reproduced in the order, ordinarily requires contempt proceedings to be dealt with by a Bench of not less than two Members, subject to the stated exception for contempt in a Member’s view, presence, or hearing.

The Tribunal also relied on Rule 24 of the CAT (Procedure) Rules, 1987, which authorises orders or directions necessary or expedient to give effect to its orders, prevent abuse of process, or secure the ends of justice.

It referred to a Supreme Court order dated 14 February 2025 in Tirthankar Basu & Ors. v. Nivedita Shukla Verma & Ors., in which contempt proceedings were closed after compliance, as support for ending proceedings where their continuation would serve no useful purpose.

Both parties confirmed that the underlying directions had been complied with, leaving no surviving grievance about implementation.

The Tribunal therefore treated the matter as requiring no further adjudication: it expressly made no finding on wilful disobedience, guilt, or exoneration and issued no substantive or coercive direction.

In those circumstances, it considered that keeping the petition pending solely to place it before a two-Member Bench would unnecessarily prolong the process.

Relying on Rule 24 and the cited Supreme Court order, it concluded that the proceeding could be brought to an end.

It dropped the contempt petition as unnecessary in view of compliance and discharged the notices, without deciding whether any wilful contempt had occurred; there was no order as to costs.