Contempt jurisdiction cannot reassess implementation merits once compliance with the underlying order is shown.

The applicants filed eight contempt petitions alleging non-compliance with the Tribunal’s common order dated 6 March 2024.

They contended that they had not been considered for appointment despite vacancies said to remain available, and challenged the respondents’ vacancy audit report.

The respondents relied on the audit report and maintained that the direction had been complied with.

The Tribunal noted that the 6 March 2024 order had been challenged before the Chhattisgarh High Court, which, by its order dated 5 December 2025, directed recalculation of vacancies and consideration of eligible applicants if vacancies remained.

1. Whether the respondents had complied with the Tribunal’s order, as clarified by the High Court’s directions, so as to defeat the contempt allegations.

2. Whether the Tribunal could examine the correctness of the vacancy audit report and the applicants’ claims on their merits in contempt proceedings.

In Union of India v. Subedar Devassy P.V. (decided 10 January 2006), the Supreme Court held that a contempt court must confine itself to the order alleged to have been breached; it cannot test the order’s correctness, vary its directions, or grant additional relief. A party disputing an order or its implementation must approach the court that made the order or invoke appellate jurisdiction.

The Tribunal also relied on M.K. Sthapak v. Prashant Mehta, Contempt Case No. 196/2018 (decided 27 April 2018), for the principle that, once an order has been complied with, its correctness on the merits cannot be examined in contempt jurisdiction.

The High Court’s direction was limited to recalculating vacancies and considering the applicants if vacancies remained and they were eligible.

The respondents had filed a vacancy audit report, which the Tribunal treated as demonstrating compliance with the direction.

The applicants’ challenge to the vacancy position and audit report raised questions about the merits and correctness of the respondents’ action, which the Tribunal held could not be adjudicated in contempt proceedings.

It closed all eight contempt petitions, discharged the alleged contemnors from the contempt notices, and left the applicants at liberty to pursue any continuing grievance by filing an Original Application.