Contempt jurisdiction cannot be used to supplement original judgments or grant reliefs not specifically ordered.

The Petitioner filed a Contempt Petition (CP) alleging non-compliance with the Tribunal’s order dated 25.06.2025

In the original order, the Tribunal directed the Disciplinary Authority (DA) to complete the disciplinary proceedings within 90 days of receiving the order, failing which the proceedings would be "deemed to have been quashed"

The Respondent received the order on 30.06.2025 and referred the matter to the Union Public Service Commission (UPSC) for mandatory advice on 27.08.2025, within the 90-day window

The UPSC provided its advice on 12.12.2025, and the DA passed the final order of punishment on 05.02.2026

The Petitioner argued that because the final order was passed after the 90-day period, the proceedings stood quashed and he was entitled to consequential benefits

1. Whether the Respondent committed willful and deliberate disobedience of the Tribunal's order by passing the final order beyond the 90-day stipulated period

2. Whether the Tribunal, in its contempt jurisdiction, can grant consequential benefits that were not explicitly directed in the original judgment

The Tribunal relied on the principle that civil contempt jurisdiction is limited to ensuring compliance with self-evident orders and cannot be used to supplement or modify original decisions

It cited Sudhir Vasudeva v. M. George Ravishekaran (2014) and Senthur v. T.N. Public Service Commission (2022) to establish that courts cannot travel beyond the original judgment in contempt proceedings

Regarding the scope of relief, the court applied the doctrine from Om Prakash & Ors. v. Ram Kumar & Ors. (1991) and Bharat Amratlal Kothari v. Dosukhan Samadkhan Sindhi & Ors. (2010), which holds that relief not specifically prayed for or pleaded cannot be granted

The procedural requirements of Rule 15(3)(a) of the CCS (CC&A) Rules, 1965, and Rule 8 of the CCS (Pension) Rules, 2021, were also noted regarding the necessity of UPSC consultation

The Tribunal found that the Respondent had performed their primary obligation by completing their portion of the disciplinary exercise and seeking UPSC advice within 58 days of receiving the order, well within the 90-day limit

The subsequent delay was attributed to the UPSC, which was not a party to the original litigation

Consequently, the Tribunal determined that the "deemed quashing" clause was not triggered because the DA had acted timeously

Furthermore, the Tribunal observed that the Petitioner’s request for consequential benefits was an attempt to expand the scope of the original order. Since the original judgment dated 25.06.2025 contained no specific direction for such benefits, the Tribunal ruled it could not issue new directions under the guise of contempt jurisdiction

The prayer for consequential benefits was rejected as it fell outside the scope of the original judgment and the nature of contempt proceedings. Accordingly, the Contempt Petition was dropped, the notice to the contemnor was discharged, and no costs were awarded