Contempt jurisdiction cannot be used to adjudicate fresh merits or vary the scope of original directions.

The writ petitioner, a Lecturer appointed in 1979 at G.D.M. College, Nalanda, sought payment of salary arrears and pensionary benefits, arguing his institution was governed by the "Vitt Sahit" (Grant-in-aid) policy rather than the "Vitt Rahit" (Self-financing) policy of 1982.

A Single Judge directed the State to calculate and pay admissible financial assistance on 27.03.2018, a decision affirmed by the Division Bench and the Supreme Court.

During subsequent contempt proceedings (M.J.C. No. 4570 of 2018), the University calculated the dues at ₹54,96,294.

The Single Judge, via order dated 03.04.2025, directed the State to disburse this amount while leaving the petitioner's right to challenge the specific calculation open.

Both the petitioner (seeking higher scales) and the State (challenging the scope of contempt directions) filed these intra-court appeals.

Whether an intra-court appeal is maintainable against directions issued by a Single Judge while exercising contempt jurisdiction.

Whether the Single Judge exceeded the scope of contempt jurisdiction by directing the disbursement of calculated funds.

Whether the court in contempt proceedings can adjudicate disputed questions regarding specific pay scales (e.g., ₹400-950 vs ₹700-1600).

The court primarily relied on the principles governing appeals in contempt matters as summarized in Midnapore Peoples' Co-operative Bank Ltd. v. Chunilal Nanda (2006), which stipulates that while Section 19 of the Contempt of Courts Act only allows appeals against punishment, any merit-based directions issued in contempt proceedings are challengeable via intra-court appeals.

The court also applied the doctrine that contempt jurisdiction is limited to verifying "willful or deliberate defiance" of the original order and does not extend to adjudicating new disputes or traveling beyond the original judgment's scope.

The Court analyzed the maintainability of the State's appeal, concluding that since the Single Judge issued a fresh direction for disbursement, an intra-court appeal was the appropriate remedy.

On merits, the Court found that the University had already calculated the dues in purported compliance with the 2018 writ order.

The Court reasoned that once a calculation is submitted by the authorities themselves, a direction for the State to disburse that specific amount does not constitute an "excess" of jurisdiction but rather a means to ensure the original order’s "letter and spirit" is met.

Regarding the petitioner's claim for a higher pay scale (₹700-1600), the Court held that such factual disputes cannot be resolved in contempt proceedings; the petitioner must initiate separate proceedings to challenge the University's specific calculation.

It held that the Single Judge's order was valid as it effectively sought compliance without overstepping into fresh adjudications of merit.

The Court directed the State and University to ensure immediate compliance with the disbursement of ₹54,96,294 to the petitioner, while reserving the petitioner's right to challenge the pay scale calculation through appropriate legal channels.

No orders as to costs were made.