Contempt jurisdiction cannot grant fresh relief beyond explicit directions absent willful disobedience.

The applicant, a Clerk-cum-Typist working on a temporary basis since 31 March 1982 under the Human Reproduction Research Centre, ICMR, at SCB Medical College and Hospital, Cuttack, retired on 30 April 2022 without regularisation.

Relying on the Madras Bench’s decision in OA No. 1332/2000, upheld by the Madras High Court and the Supreme Court, he sought regularisation.

In OA No. 25/2020, the Tribunal directed the respondents to regularise him retrospectively from the date on which similarly situated employees were regularised, notionally fix his pay, and grant pensionary benefits from the date of retirement.

The applicant thereafter initiated contempt proceedings alleging non-compliance.

During the contempt proceedings, however, regularisation and payment of pensionary benefits were not disputed.

His remaining grievance concerned deductions from his sanctioned retirement gratuity of ₹14,17,251 towards the employer’s CPF contribution and interest.

The respondents stated that, after the deductions, ₹22,600 was paid to him and that the CPF calculation was made in accordance with the applicable rules and the available CPF records.

Whether the respondents wilfully disobeyed the Tribunal’s directions in OA No. 25/2020 by failing to regularise the applicant and grant the consequential pensionary benefits.

Whether the correctness of deductions made from the applicant’s retirement gratuity towards the employer’s CPF contribution and interest could be adjudicated in the contempt proceedings.

Whether the Tribunal could issue supplementary or consequential directions beyond the express terms of the original order while exercising contempt jurisdiction.

Contempt jurisdiction is attracted only upon proof of wilful disobedience of a specific court or tribunal direction.

The contempt court must confine its examination to the express terms of the original judgment and cannot travel beyond that judgment or grant fresh, supplementary, or incidental relief not contained in the original order.

Contempt jurisdiction exists to secure compliance with an existing order, not to adjudicate a new entitlement or determine disputed consequential claims.

The Tribunal relied on V.M. Manohar Prasad v. N. Ratnam Raju, (2004) 13 SCC 610, and Snehasis Giri v. Subhasis Mitra, (2023) 18 SCC 529, for these principles.

The original direction in OA No. 25/2020 required retrospective regularisation, notional pay fixation, and grant of pension from the date of retirement.

The Tribunal found that the substantive directions in the original order had been complied with: the applicant had been regularised and had received pension and other admissible consequential benefits.

Therefore, no wilful disobedience of the Tribunal’s express directions was established.

The applicant’s challenge to the computation of CPF deductions and the amount of gratuity paid raised a separate dispute concerning the correctness of financial calculations.

Since the original order did not contain any specific direction regarding the precise computation or payment of the disputed gratuity amount, the Tribunal held that it could not determine that issue in contempt jurisdiction or enlarge the scope of the original proceedings.

The grievance regarding deductions from the retirement gratuity could not be examined or converted into a fresh monetary claim in contempt proceedings.

The contempt petition was accordingly dropped, the notices were discharged, and the parties were directed to bear their own costs.