CAT - ['Delhi']
Employment and Labour LawAdministrative and Public Law

Applicants may revive contempt proceedings within four weeks if Tribunal directions remain incompletely complied with.

Prakash Rathod vs MS. PUNYA SALILA SRIVASTAVA, SECRETARY, M/O HEALTH AND FAMILY WELFARE

CAT - ['Delhi']JUDGMENT: September 01, 20262 MIN READSOURCE JUDGMENT
Applicants may revive contempt proceedings within four weeks if Tribunal directions remain incompletely complied with.. Prakash Rathod vs MS. PUNYA SALILA SRIVASTAVA, SECRETARY, M/O HEALTH AND FAMILY WELFARE. CAT - ['Delhi']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants, serving as Staff Nurses at Dr. Ram Manohar Lohia Hospital, instituted Contempt Petition No. 745/2025 alleging non-compliance with the directions issued by the Tribunal in OA No. 1877/2019.

Source reference: p.1

The respondents relied upon a sanction order dated 14 May 2026 and payment details to submit that the Tribunal’s directions had been fully complied with.

Source reference: p.3

The applicants disputed complete compliance, submitting that two applicants had not yet received their full benefits.

Source reference: p.3

They requested an order similar to that passed by a Coordinate Bench in CP No. 737/2025 in OA No. 2527/2022, granting liberty to approach the Tribunal in case of default.

Source reference: p.3
02

Issues

1. Whether the respondents had fully complied with the directions issued by the Tribunal in OA No. 1877/2019.

Source reference: p.3

2. Whether the applicants should be granted liberty to revive or re-approach the contempt proceedings if the directions were not fully complied with within a specified period.

Source reference: p.3
03

Law Applied

The Tribunal applied the principle that contempt proceedings may be closed where the alleged contemnors demonstrate compliance with the underlying judicial directions, while reserving liberty to the aggrieved applicants to seek further directions if compliance remains incomplete.

Source reference: p.3

The Tribunal also followed the approach adopted by its Coordinate Bench in CP No. 737/2025 in OA No. 2527/2022, under which petitioners were permitted to approach the Tribunal by way of an appropriate miscellaneous application in the event of default.

Source reference: p.3

No specific statutory provision or substantive precedent was cited in the order.

Source reference: p.3
04

Reasoning

Although the respondents asserted full compliance on the basis of the sanction order and payment details, the applicants maintained that two applicants had not received their complete benefits.

Source reference: p.3

Rather than finally determining the disputed extent of payment at that stage, the Tribunal adopted the course followed by the Coordinate Bench and protected the applicants’ position by granting them liberty to revive the matter if complete compliance did not occur within four weeks.

Source reference: p.3

This balanced the respondents’ assertion of compliance with the applicants’ contention that some benefits remained unpaid.

Source reference: p.3
05

Holding

The Tribunal closed CP No. 745/2025, granting the applicants liberty to revive the contempt petition if the Tribunal’s directions were not fully complied with within four weeks.

The notices were discharged.

Source reference: p.4
CAT - ['Delhi']

Original Court PDF

Prakash RathodvsMS. PUNYA SALILA SRIVASTAVA, SECRETARY, M/O HEALTH AND FAMILY WELFARE

CAT - ['Delhi'] · September 01, 2026

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