Belated Compliance with Time-Bound Directions Does Not Absolve Contempt but Warrants Costs Against Erring Officers

The Petitioner, appointed as a vaccinator in 1990 and later a Vaccination Inspector in 1999, sought promotion to the vacant post of Chief Vaccinating Inspector

Due to administrative inaction, he filed O.A. No. 2978/2019 before the Central Administrative Tribunal (CAT). On 24.02.2020, the CAT directed the Respondent to decide the Petitioner's representation by 29.02.2020 via a reasoned order

The Respondent failed to comply by the deadline. After the Petitioner initiated contempt proceedings (C.P. No. 266/2021), the Respondent passed a speaking order on 16.11.2022—more than 2.5 years late—stating the grievance would be considered in a future DPC

The CAT subsequently closed the contempt proceedings, leading to this writ petition challenging that closure

1. Whether the Respondent’s passing of a speaking order after a delay of 2 years and 8 months constituted sufficient compliance with the Tribunal’s time-bound directions

2. Whether the Court can hold an abstract entity (the Commissioner/Department) liable for contempt without the impleadment of specific natural persons as contemnors

The court applied the principles of contempt jurisdiction, which require proof of "wilful disobedience" of a court order

It emphasized that contempt is a quasi-criminal jurisdiction directed against natural persons rather than abstract institutions, necessitating the impleadment of specific individuals to satisfy procedural fairness and natural justice

Furthermore, the court referred to the principle that while administrative delays (such as municipal unification or DPC logistics) may explain tardiness, they do not excuse the failure to seek an extension of a binding judicial timeframe

The Court observed that the Respondent was fully aware of the CAT's order and the specific 29.02.2020 deadline, which was linked to the Petitioner's superannuation

The Respondent neither challenged the order nor sought an extension, rendering the two-and-a-half-year delay an act of "manifest administrative indifference"

However, the Court identified a foundational defect in the petition: even though the conduct was "lethargic" and showed a "dearth of accountability" [p. 9], the Petitioner failed to implead the specific officers responsible

The Court reasoned that while the Respondent's approach was unsatisfactory, it could not "judicially rewind" the clock at this belated stage

To balance justice without further prolonging the litigation, the Court determined that the public exchequer should not bear the cost of individual negligence

The Court disposed of the petition by directing the Respondent to pay a cost of ₹2,00,000 to the Petitioner within four weeks as a measure of substantive justice [p. 10-11, para. 21]. Notably, the Respondent was granted liberty to recover this amount from the salaries of the "erring officers" responsible for the delay