Contempt jurisdiction cannot be exercised to test the correctness of a reasoned order passed upon remand.

The petitioner, Horil Mandal, was engaged as a daily wager in the Bihar State Agriculture Produce Marketing Board and recommended for regular appointment in 1990

Following the dissolution of the Board via the Repeal Act, 2006, his services were terminated on 21.02.2007

The petitioner challenged this in CWJC No. 4636 of 2007, where the Court, on 15.12.2015, set aside the termination and remitted the matter to the Agriculture Department for fresh consideration

The petitioner filed the present contempt petition alleging non-compliance with the 2015 order, as his claim was subsequently rejected by the Secretary, Agriculture Department via Memo No. 1440 dated 18.12.2020 after a hearing

1. Whether the act of rejecting the petitioner's representation through a reasoned order constitutes a willful disobedience or contempt of the writ court's directions for "fresh consideration"

2. Whether a court exercising contempt jurisdiction can examine the correctness or merits of a new order passed by the authorities pursuant to the court's earlier directions

The court relied on the established principles of contempt jurisdiction, primarily citing State of Bihar & Ors. v. Rajendra Singh & Anr. (Civil Appeal No. 6356 of 2000), which dictates that a contempt court is only concerned with whether a decision has been complied with, not its correctness

It also referenced Bhaskar Govind Gavate v. State of Maharashtra and Indian Medical Association & Anr. v. Union of India & Ors. regarding the purpose of contempt jurisdiction to uphold the majesty of law and administration of justice

The core doctrine applied is that once a "reasoned order" is passed in compliance with a remand, the contempt proceedings are concluded, and the new order must be challenged separately

The Court observed that the original writ order dated 15.12.2015 did not grant an absolute right to reinstatement but directed the Secretary of the Agriculture Department to consider the case "afresh"

The opposite parties demonstrated that a Three-Member Committee was constituted, the petitioner was heard via video conferencing, and a formal reasoned order was passed on 18.12.2020 rejecting the claim

The Court reasoned that since the authority had performed the directed act (consideration), the "rightness or wrongness" of that rejection cannot be adjudicated within contempt proceedings

To do so would improperly involve the Court in exercising review jurisdiction over a fresh administrative decision, which exceeds the scope of a contempt inquiry

The contempt petition was dismissed, concluding that once a decision is taken/order passed by the authority as directed, the contempt jurisdiction ends. Holding that it cannot test the validity of the new order in this proceeding, the Court granted the petitioner liberty to challenge Memo No. 1440 dated 18.12.2020 through appropriate legal channels