CAT has power to condone delay in filing contempt petitions by applying Section 21 of Administrative Tribunals Act.

The applicant, a former Safaiwala, filed OA No. 213/2014 challenging the non-review of her suspension. On 03.11.2023, the Tribunal quashed the suspension and directed the respondents to treat the period from 28.12.2013 to 22.01.2016 as duty with full pay and allowances within three months

Despite the order being communicated on 11.01.2024, the respondents failed to comply or appeal the decision

Consequently, the applicant filed a Contempt Petition (CP) on 11.08.2025 with a four-month delay, filing the present Miscellaneous Application (MA) for condonation of that delay

The respondents objected, arguing the Tribunal lacks the power to condone delay beyond the one-year limitation prescribed under Section 20 of the Contempt of Courts Act, 1971

1. Whether the Tribunal has the power to condone delay in filing a Contempt Petition under the Administrative Tribunals Act, 1985

2. Whether the applicant demonstrated "sufficient cause" for the four-month delay in filing the present contempt proceedings

The Tribunal applied Rule 22 of the Central Administrative Tribunal (Contempt of Courts) Rules, 1992, which mandates that for matters not specifically provided for in the Contempt Rules, the procedure prescribed in the Administrative Tribunals Act (ATA), 1985, applies mutatis mutandis

It specifically relied on Section 21 of the ATA, 1985, which governs limitation and specifically sub-section (3) which empowers the Tribunal to admit applications after the limitation period if "sufficient cause" is shown

Regarding substantive contempt law, it considered Section 20 of the Contempt of Courts Act, 1971, alongside the precedents of Pallav Sheth v. Custodian and Maheshwar Peri v. High Court of Judicature at Allahabad

The Tribunal rejected the respondents' technical objection that the one-year limit under Section 20 of the Contempt of Courts Act is absolute and bars the Tribunal's jurisdiction to condone delay. The Bench reasoned that because the CAT (Contempt of Courts) Rules do not explicitly address limitation procedures, the enabling provisions of Section 21 of the ATA, 1985, must apply mutatis mutandis

The court noted that Section 21(3) provides an express statutory power to condone delay upon satisfaction of sufficient cause, thereby distinguishing it from the limitations cited in the respondents' precedents

Applying this to the facts, the Tribunal observed that the applicant had been diligently pursuing her case and that the respondents had neither complied with nor challenged the original order of 03.11.2023

The court held that a government organization cannot be permitted to ignore a judicial verdict without valid reason, and found the four-month delay to be reasonably explained

It held that the Tribunal possesses the power to condone delay in contempt matters under Section 21(3) of the ATA, 1985

The respondents were granted a final three months to comply with the original order dated 03.11.2023, with a warning that failure to do so would result in proceedings against erring officers under the 1992 Rules. The Contempt Petition was listed for 25.05.2026