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 Repeal Act of 2006, the Board was dissolved and the petitioner’s services were terminated in 2007

The petitioner challenged this in CWJC No. 4636 of 2007, where the High Court, on 15.12.2015, set aside the termination and remitted the matter to the Agriculture Department for fresh consideration, noting that the Bazar Samiti was competent to make Class IV appointments

The present contempt petition (MJC) was filed alleging non-compliance with the 2015 direction

During the pendency of this MJC, the Secretary of the Agriculture Department heard the petitioner and passed an order dated 18.12.2020 rejecting the claim

1. Whether the opposite parties committed contempt of court by failing to comply with the order dated 15.12.2015 in its true spirit

2. Whether the Court, in its contempt jurisdiction, can examine the correctness or legality of a fresh reasoned order passed by the authority pursuant to a remand

State of Bihar Ors. v. Rajendra Singh Anr. (2004), which dictates that a contempt court is only concerned with whether the decision was complied with, not its correctness

Bhaskar Govind Gavate v. State of Maharashtra (2022) and Indian Medical Association v. Union of India (2024) regarding the duty of courts to uphold the majesty of law and ensure substantial compliance

The core doctrine is that a contempt court cannot traverse beyond the original order or exercise review jurisdiction over a new order passed by the contemnor

The Court observed that the original writ jurisdiction order dated 15.12.2015 did not grant an automatic reinstatement but remitted the matter for "fresh consideration"

The opposite parties demonstrated that they complied with this direction by constituting a committee, providing a personal hearing to the petitioner via video conferencing, and passing a reasoned order on 18.12.2020

Although the petitioner argued that the 2015 judgment had already declared his appointment permanent and the fresh rejection was in "teeth" of that finding, the Court held that once a reasoned order is passed following a remand, the contempt jurisdiction is exhausted

Testing the "rightness or wrongness" of the new order would amount to exercising review jurisdiction, which is impermissible in contempt proceedings

The contempt petition was dismissed. The petitioner was granted liberty to challenge the legality of the fresh rejection order in an appropriate proceeding