Contempt jurisdiction cannot reopen disputed vacancy claims or enlarge the original judgment’s directions.

In the underlying O.A., the Tribunal’s order dated 23 April 2025 quashed the impugned orders and directed the respondents to prepare and publish a General-category wait list for the relevant recruitment and offer appointments according to merit, subject to the specified conditions and limitations.

The applicant initiated contempt proceedings alleging non-compliance.

The respondents stated that they had issued a wait list on 19 December 2025, but the applicant was not included because, according to them, only one relevant UR vacancy was available and it was allocated to another wait-listed candidate.

The applicant disputed the vacancy assessment, relying on later recruitment activity, a representation, and RTI information showing vacancies.

1. Whether the respondents’ actions amounted to wilful or deliberate disobedience of the operative directions in the order dated 23 April 2025.

2. Whether the applicant’s objections concerning the vacancy position and entitlement to appointment could be adjudicated in contempt proceedings.

Contempt jurisdiction is confined to determining whether the specific, express directions in the order alleged to have been breached were wilfully disobeyed; it cannot be used to reopen decided issues, adjudicate matters not decided in the original order, or enlarge or supplement that order.

In Sudhir Vasudeva, Chairman and Managing Director, ONGC Ltd. v. M. George Ravishekaran, (2014) 3 SCC 373, the Supreme Court held that contempt courts must remain within the four corners of the order and cannot issue supplemental directions or exercise the functions of review or appeal.

The Tribunal also referred to Er. K. Arumugam v. V. Balakrishnan, Dr. U.N. Bora, Ex. Chief Executive Officer v. Assam Roller Flour Mills Association, (2022) 1 SCC 101, and Chaduranga Kanthraj Urs v. P. Ravikumar in reiterating these limits.

The original order required the respondents to conduct a defined exercise: prepare and publish the General-category wait list and make appointments in accordance with merit and the order’s stated conditions.

The respondents placed on record that they had prepared and issued a wait list and explained why the applicant was not included.

The applicant’s challenge required examination of recruitment records, the chronology and character of vacancies, the applicability of the DoPT O.M. dated 13 June 2000, and his entitlement to appointment against particular vacancies.

Those questions were not suitable for determination in contempt proceedings, and disagreement with the respondents’ assessment did not, without more, establish wilful disobedience.

It closed the petition and discharged the notices, while leaving the applicant at liberty to pursue appropriate proceedings before the proper forum; no opinion was expressed on the merits of either party’s position.