Contempt jurisdiction cannot extend beyond factual implementation of original directions to adjudicate fresh claims for subsequent promotions.

The petitioner, a Daffadar (Group ‘C’) in the Survey of India, filed a Contempt Petition alleging willful disobedience of the Tribunal’s order dated 19.04.2023.

The original order directed the respondents to implement an administrative order dated 03.10.2018, which mandated promoting eligible employees subject to training completion, with notional pay parity to juniors.

The respondents initially challenged this in the Delhi High Court (WP(C) No. 10963/2024), which was disposed of on 21.08.2024 with directions to follow the department's compliance plan.

Subsequently, the respondents classified the petitioner as Planetabler Grade-IV w.e.f. 01.01.2021, fixed his pay notionally from 01.07.2005 (his junior's date), and paid arrears of ₹65,826.

The petitioner contested this, claiming he was entitled to further promotions (Grade-III to Survey Assistant) at par with other juniors like D.V. Pradhan.

1. Whether the respondents' actions in granting Grade-IV classification and notional pay parity constitute substantial compliance with the Tribunal’s directions dated 19.04.2023.

2. Whether the petitioner's claim for further promotions to Grade-III, Grade-II, and Survey Assistant can be adjudicated within the scope of contempt jurisdiction.

The Tribunal applied the well-settled principle that contempt jurisdiction is strictly confined to examining whether there has been a "wilful and deliberate disobedience" of a specific court order.

The scope of a Contempt Petition cannot exceed the "ambit of the original order" nor can it adjudicate new claims or factual disputes regarding eligibility for higher grades that depend on fresh conditions like trade tests.

The Tribunal compared the specific directions in the original order (implementing the 03.10.2018 order) with the respondents' compliance affidavits. It found that because the respondents granted the Grade-IV promotion after training and provided notional pay parity with the identified junior (Ram Prasad Yadav), the core direction was "substantially complied with".

Regarding the petitioner's demand for higher grades (Grade-III etc.), the Tribunal reasoned that such promotions are contingent upon fulfilling eligibility criteria and passing trade tests, which were not part of the mandatory directions in the original order.

Furthermore, the comparison with other juniors like D.V. Pradhan required a detailed examination of service records, which constitutes an independent cause of action unsuitable for summary contempt proceedings.

The Contempt Petition was closed, the notices issued to the respondents were discharged, and the delay in compliance was condoned in light of the unconditional apology and subsequent corrective actions, while granting the petitioner liberty to pursue fresh legal remedies for any subsisting grievances regard higher-level promotions.