### Contempt Jurisdiction Cannot Be Used to Adjudicate Substantive Disputes Regarding Calculation of Quantified Arrears or Pay Scales

The writ petitioner, a Lecturer appointed in 1979 at G.D.M. College, sought salary arrears and pensionary benefits equivalent to employees of "deficit grant" affiliated colleges, arguing his appointment predated the 1982 "Vitt Rahit Shiksha Niti" (no-aid policy).

A Single Judge allowed the writ petition (C.W.J.C. No. 8120 of 2016), directing the State to work out admissible financial assistance.

This was upheld by the Division Bench and subsequently by the Supreme Court.

Due to non-compliance, contempt proceedings (M.J.C. No. 4570 of 2018) were initiated.

During contempt, the University calculated arrears at Rs. 54,96,294, but the petitioner disputed the pay scale.

The State challenged the contempt order, arguing it exceeded the original judgment.

Both parties appealed the Single Judge’s disposal of the contempt petition dated 03.04.2025.

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 the original judgment by directing the State to disburse a specific calculated amount in a contempt proceeding.

Whether the petitioner can challenge the merits of the University's calculation within the scope of contempt proceedings.

The court primarily relied on the principles governing appeals in contempt matters established in *Midnapore Peoples' Co-operative Bank Ltd. v. Chunilal Nanda*, which holds that while Section 19 of the Contempt of Courts Act only allows appeals against punishment, any direction issued on the merits of a dispute during contempt is challengeable via intra-court appeal.

It further applied the principle that contempt jurisdiction is limited to ensuring willful compliance and cannot be used to adjudicate new disputes or travel beyond the original decree.

The Court analyzed the maintainability of the appeals, noting that under the *Midnapore* precedent, the High Court possesses the power to hear intra-court appeals if a contempt order decides an issue on merit.

Regarding the State’s appeal, the Court found that the Single Judge did not exceed jurisdiction but merely ensured the "letter and spirit" of the original 2018 order was followed by directing the disbursement of the amount the University itself had quantified.

The Court noted that the petitioner’s right to aid had already been "crystallized" prior to 1982, a fact affirmed by the Supreme Court.

Addressing the petitioner’s appeal, the Court reasoned that the contempt court is not the forum to adjudicate factual disputes regarding pay scales (e.g., Rs. 400-950 vs. Rs. 700-1600); such grievances must be raised through fresh appropriate legal applications.

It held that the State is liable to disburse the calculated amount of Rs. 54,96,294 to the petitioner.

The petitioner's claim for a higher pay scale remains open for challenge in separate proceedings, but not within the contempt jurisdiction.

The Court directed the State and University to ensure immediate compliance.