Compliance with Court Directions Requiring Reasoned Orders via Similar Treatment of Factually Identical Claimants Negates Wilful Contempt.

The petitioner sought contempt proceedings alleging violation of a coordinate Bench judgment dated September 3, 2020. That judgment directed the State to pay salaries to teachers at parity with regular Higher Secondary teachers from July 2010 to December 2013.

While the High Court granted liberty to petitioners to seek arrears upon production of records, the alleged contemnor passed an order on January 15, 2025, denying the claim partly on the ground that the initial appointment was contractual—a reasoning the petitioner argues contradicts the 2020 judgment.

Meanwhile, the Supreme Court, in related proceedings on January 6, 2026, directed the State to consider fresh representations from similarly situated teachers after allowing them to inspect school records.

1. Whether the order dated January 15, 2025, passed by the respondent constitutes willful and deliberate contempt of the judgment dated September 3, 2020

2. Whether the petitioner, who was not a party to the specific contempt petitions before the Supreme Court, is entitled to the same procedural reliefs granted by the Apex Court to similarly circumstanced candidates

when an authority passes a reasoned order (whether correct or incorrect) in purported compliance with a judicial direction, it does not generally constitute "willful and deliberate" contempt; the remedy for an erroneous order lies in fresh litigation, as established in J.S. Parihar v. Ganpat Duggar & Ors. (1996) 6 SCC 291

directions in State of West Bengal v. Anirban Ghosh (SLP Civil 14355/21), which mandated that benefits granted to successful litigants must be extended to all "similarly placed" persons to avoid creating disparate classes of employees

The Court observed that while the petitioner alleged the January 15, 2025 order was contumacious for ignoring the Bench's observation regarding contractual status, the act of passing a reasoned order—rightly or wrongly—precludes a finding of contempt under the J.S. Parihar doctrine.

The Apex Court explicitly directed the State to treat all similarly placed candidates uniformly.

Consequently, the High Court reasoned that denying the petitioner the same procedural safeguards (fresh representation, hearing, and inspection of records) granted by the Supreme Court to others would create an impermissible "two-class" system among similarly situated teachers.

the Court disposed of the petition by granting the petitioner liberty to file a fresh representation within a fortnight. The Secretary, School Education Department, was directed to consider this representation afresh, uninfluenced by the previous order of January 15, 2025, and to follow the specific procedural steps (including hearing and record inspection) outlined by the Supreme Court in its order dated January 6, 2026. The exercise must be completed within three months.