Compliance based on rational recruitment methodology and category-wise candidate availability does not constitute contumacious contempt.

The petitioners filed a Contempt Petition (CP) alleging that the respondents failed to comply with the Tribunal’s order dated 25.02.2025.

In the original O.A., the Tribunal found anomalies in the second round of document verification (DV) where cut-off marks for UR were reduced but those for EWS/SC/OBC were not.

The Tribunal had directed the respondents to reduce cut-off marks for the second round for these reserved categories specifically for candidates who secured above 71.286850 marks without taking relaxations.

The respondents filed compliance and additional affidavits explaining that seven of the 20 applicants were empanelled after being called for DV/ME.

They clarified that for the remaining candidates, cut-offs were not lowered in the second round because sufficient candidates were already available from the first round, though cut-offs were progressively lowered in subsequent rounds (up to the 7th round) to fill vacancies.

1. Whether the respondents committed willful, deliberate, and contumacious contempt of the Tribunal’s directions dated 25.02.2025 regarding the recalculation of cut-off marks and empanelment of reserved category candidates.

The Tribunal applied the principles governing contempt of court, which require a finding of "willful and deliberate" disobedience of a judicial order.

It further relied on the legal principles established by the Supreme Court of India in Union of India v. Ramesh Ram Ors., which dictates the methodology for the adjustment and migration of "Meritorious Reserved Candidates" (MRC) against Unreserved (UR) vacancies to ensure that high-performing reserved candidates are not disadvantaged by their merit.

The recruitment was also governed by the terms of Employment Notification No. CEN RRC-01/2019.

The Tribunal examined the respondents’ explanation for the stagnation of cut-off marks during the second round of DV. The respondents demonstrated that the recruitment process involved 17 different Level-1 posts where post preferences and medical fitness played a crucial role in empanelment.

The respondents explained that after the first round, sufficient candidates in SC, OBC, and EWS categories were available to fill the then-existing vacancies, obviating the need to lower the cut-off initially.

The Tribunal found that the respondents had exercised due diligence by adjusting Meritorious Reserved Candidates who scored above 71.286850 against UR vacancies in strict adherence to the 25.02.2025 order.

The presence of the Chairman of the Railway Recruitment Cell and the detailed breakdown of the seven rounds of DV satisfied the Tribunal that the methodology was based on administrative necessity and objective criteria rather than an intent to circumvent the Court's order.

The Tribunal concluded that the respondents had performed due diligence and carried out the recruitment process, including the determination of cut-off marks and post-preferences, in accordance with the rules and the Tribunal's directions.

The Contempt Petition was closed, and the notices issued to the respondents/contemnors were discharged.