Compliance with a direction to consider a representation precludes a finding of willful disobedience.

The Petitioner, a widow of a deceased Prasar Bharati employee, originally filed a Writ Petition [W.P. (C) No. 1227/2025] before the Delhi High Court.

On 31.01.2025, the High Court issued an interim direction to the Secretary, Ministry of Information and Broadcasting (Respondent No. 1), to consider a requisition sent by the CEO of Prasar Bharati regarding certain benefits and take a decision within four weeks.

The matter was later transferred to the Central Administrative Tribunal (CAT).

The Petitioner filed this contempt petition alleging willful disobedience of the High Court's order.

The Respondents submitted that they complied by passing a speaking order on 01.04.2025, which rejected the Petitioner's claim for benefits under Rule 10 of the CCS (Implementation of NPS) Rules, 2021, and they tendered an unconditional apology for the procedural delay.

1. Whether there is willful disobedience of the order dated 31.01.2025 on the part of the respondents given that a speaking order has been passed during the pendency of the proceedings?

Section 2(b) of the Contempt of Courts Act, 1971, which defines "civil contempt" as the willful disobedience of any judgment or order.

Director of Education, Uttaranchal v. Ved Prakash Joshi (2005), establishing that a contempt court cannot examine the correctness of the original decision or traverse beyond the order.

Union of India v. Subedar Devassy PV (2006), noting that even if an order is wrong, it must be obeyed, and the court cannot exercise review jurisdiction under the guise of contempt.

Uttar Pradesh v. A.K. Earth Movers (2017), holding that once a representation is decided as directed, any remaining grievance constitutes a fresh cause of action.

The Tribunal examined whether the Respondents' actions met the threshold of "willful disobedience." It noted that the specific mandate of the High Court's interim order was to "consider" the request and "take a decision".

The Respondents provided evidence that they consulted the Department of Expenditure (Ministry of Finance) and subsequently issued a compliance order on 01.04.2025.

The Tribunal reasoned that since a decision (the speaking order) was actually rendered and communicated to the Petitioner, the mandate of the court had been fulfilled.

The court emphasized that it cannot adjudicate the merits or the "rightness" of the rejection within contempt jurisdiction, as such determination would overstep its legal boundaries.

The Contempt Petition was dismissed, and the respondents were discharged; however, the court granted the Petitioner liberty to challenge the correctness and merits of the compliance order dated 01.04.2025 through appropriate legal proceedings, as it constitutes a fresh cause of action.