CAT - ['Delhi']
Administrative and Public LawCivil Procedure and Evidence

Contempt petition becomes infructuous upon respondents’ compliance with the direction to pass a speaking order.

Anuradha Kumari vs Sh. Ashok Kumar Singh, Director General, EMPLOYEES STATE INSURANCE CORPORATION (ESIC) and anr

CAT - ['Delhi']JUDGMENT: September 21, 20262 MIN READSOURCE JUDGMENT
Contempt petition becomes infructuous upon respondents’ compliance with the direction to pass a speaking order.. Anuradha Kumari vs Sh. Ashok Kumar Singh, Director General, EMPLOYEES STATE INSURANCE CORPORATION (ESIC) and anr. CAT - ['Delhi']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants had filed O.A. No. 454/2026 concerning their representation dated 24 January 2026.

Source reference: para. 1; p. 3

On 6 February 2026, the Tribunal directed the competent authority of the respondents to consider and dispose of the representation by passing a reasoned and speaking order within 45 days of receiving the certified copy of the order, and to grant consequential relief within a further period of 45 days if the decision was in the applicants’ favour.

Source reference: para. 1; p. 3

The applicants thereafter instituted the present contempt petition, alleging non-compliance with the Tribunal’s directions.

Source reference: para. 2–3; p. 3

During the pendency of the contempt petition, the respondents passed a speaking order dated 12 May 2026, a copy of which was received by the applicants.

Source reference: para. 2–3; p. 3

The applicants’ counsel confirmed such receipt before the Tribunal.

Source reference: para. 2–3; p. 3
02

Issues

Whether the respondents had complied with the directions issued by the Tribunal in O.A. No. 454/2026 by passing and furnishing a speaking order on the applicants’ representation dated 24 January 2026?

Source reference: para. 1–3; p. 3

Whether the contempt petition should continue after the respondents passed the speaking order and the applicants acknowledged its receipt?

Source reference: para. 3–4; pp. 3–4
03

Law Applied

The Tribunal applied the principle that a contempt or compliance petition is maintainable only so long as there is an alleged or continuing non-compliance with the operative directions of the Tribunal.

Source reference: para. 4; p. 4

Where the respondents have substantially complied with the direction by passing and furnishing the required speaking order, the contempt proceedings ordinarily serve no further purpose.

Source reference: para. 4; p. 4

The Tribunal also recognised that any independent grievance regarding the correctness, legality, or merits of the speaking order may be pursued by the applicants before an appropriate forum.

Source reference: para. 4; p. 4
04

Reasoning

The original order required the respondents to decide the applicants’ representation through a reasoned and speaking order.

Source reference: para. 2–3; p. 3

The respondents subsequently passed the speaking order dated 12 May 2026, and the applicants’ counsel expressly confirmed that the order had been received.

Source reference: para. 2–3; p. 3

Since the specific direction issued in the original O.A. had thereby been complied with, the Tribunal found no useful purpose in keeping the contempt petition pending.

Source reference: para. 4; p. 4

The Tribunal did not examine the merits or legality of the speaking order and preserved the applicants’ right to challenge any surviving grievance before an appropriate forum.

Source reference: para. 4; p. 4
05

Holding

The Tribunal held that, in view of the respondents’ compliance with the earlier direction, no further purpose would be served by continuing the contempt proceedings.

C.P. No. 555/2026 was accordingly closed, and the notices were discharged.

Source reference: para. 4–5; p. 4

The applicants were granted liberty to agitate any grievance arising from the speaking order before an appropriate forum.

Source reference: para. 4–5; p. 4

All pending miscellaneous applications, if any, were also disposed of.

Source reference: para. 4–5; p. 4
CAT - ['Delhi']

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Anuradha KumarivsSh. Ashok Kumar Singh, Director General, EMPLOYEES STATE INSURANCE CORPORATION (ESIC) and anr

CAT - ['Delhi'] · September 21, 2026

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