Contempt jurisdiction cannot adjudicate disputed compliance calculations; surviving grievances must be pursued independently.

The petitioner instituted a contempt petition alleging wilful disobedience of the Tribunal’s judgment dated 28 July 2023 in O.A. No. 2763/2022.

The original judgment directed payment of financial benefits with interest at the rate applicable to GPF deposits; it further provided that, if payment was delayed beyond six weeks from receipt of the order, the applicable interest rate would increase by 1% for each month of further delay.

During the contempt proceedings, the respondents filed successive compliance affidavits, including an affidavit dated 8 July 2026, stating that interest on gratuity, leave encashment, ACP/MACP arrears and UTEGIS had been calculated and released, including a total amount of ₹14,43,250 after approval from the Finance Department.

The petitioner accepted that the other directions had been complied with but disputed the correctness of the respondents’ interest calculation, relying on a different calculation prepared by him.

1. Whether the respondents had wilfully disobeyed the Tribunal’s directions contained in the judgment dated 28 July 2023, particularly the direction concerning payment of interest.

2. Whether the contempt jurisdiction could be used to determine whether the respondents’ interest calculation or the petitioner’s calculation was legally and mathematically correct.

The Tribunal applied the principle that contempt jurisdiction is confined to examining wilful or intentional disobedience of a clear judicial direction and cannot ordinarily be converted into a forum for adjudicating disputed substantive claims or reviewing the correctness of calculations.

The Tribunal relied on its original directions requiring payment of applicable GPF-rate interest and enhanced interest in case of delay beyond six weeks.

No statutory provision or judicial precedent was expressly cited in the order.

The respondents placed on record due-and-drawn statements, arrear calculations and interest calculations, and asserted that the directed payments had been released.

Although the petitioner disputed the amount of interest, he acknowledged that the respondents had complied with the other directions and accepted that interest calculations had been prepared and payment released.

The Tribunal held that deciding which of the competing interest calculations was correct would require adjudication of the petitioner’s surviving monetary grievance, rather than a determination of wilful contempt.

Such an exercise was beyond the permissible scope of the contempt proceedings.

It accordingly closed C.P. No. 815/2024 and discharged the contempt notices.

The petitioner was granted liberty to pursue any remaining grievance regarding the interest calculation or payment amount afresh in accordance with law.