Contempt petition dropped where compliance aligns with subsequent Supreme Court clarifications.

The petitioner, Satya Narain, filed a contempt petition alleging non-compliance with the judgment and order dated February 5, 2024, in O.A. No. 6 of 2023.

The original order directed the respondents to grant one notional increment to the applicant, issue a revised PPO, and pay arrears restricted to three years preceding the filing of the original application with simple interest at 6% per annum.

The petitioner's counsel stated that while a revised PPO was issued, the arrears and interest were not paid.

The respondents' counsel contended that compliance was undertaken in accordance with subsequent clarifications by the Hon'ble Supreme Court in `Union of India vs. M. Siddaraj` and `Director (Admn. and HR) KPTCL & Ors. vs. C.P. Mundinamani & Ors.`, decided on April 11, 2023, and reiterated that the notional increment and revised pension were processed, with any remaining grievance solely pertaining to the calculation or extent of arrears.

They cited Supreme Court interim orders dated September 6, 2024, and final directions dated February 20, 2025, from Diary No. 2400 of 2024 `(Union of India & Anr. vs. M. Siddaraj)`, which clarified the modalities of paying enhanced pension based on notional increments.

The Department of Personnel and Training also issued an Office Memorandum dated October 14, 2024, providing instructions based on the Supreme Court's orders regarding the allowance of increment for pension calculation.

1. Whether the respondents willfully disobeyed the Tribunal's order dated February 5, 2024, by not paying the full arrears and interest, despite issuing a revised PPO.

2. Whether a dispute related to the calculation or extent of arrears, clarified by subsequent authoritative pronouncements of the Supreme Court, constitutes wilful disobedience amounting to civil contempt.

The Tribunal applied the principles governing civil contempt jurisdiction, primarily focusing on determining whether there was "wilful and deliberate disobedience" of a court order.

It considered prior judgments of the Hon'ble Supreme Court, specifically `Director (Admn. and HR) KPTCL & Ors. vs. C.P. Mundinamani & Ors.`, decided on April 11, 2023, and its subsequent clarifications in `Union of India & Anr. vs. M. Siddaraj` (Diary No. 2400 of 2024), dated September 6, 2024, and February 20, 2025, which laid down specific guidelines for the payment of notional increments and enhanced pension.

The Tribunal also acknowledged the Department of Personnel and Training's Office Memorandum dated October 14, 2024, issued in pursuance of the Supreme Court's orders.

The core legal principle applied was that a dispute relating to interpretation, calculation, or consequential benefits, especially in light of subsequent authoritative pronouncements, does not amount to wilful disobedience in the context of civil contempt.

The Tribunal found that the respondents had taken steps towards compliance by issuing a revised PPO and processing the revised pension.

The remaining grievance concerned the calculation or extent of arrears and interest.

The court acknowledged that the respondents had proceeded based on subsequent binding directions from the Hon'ble Supreme Court in `C.P. Mundinamani` and `M. Siddaraj`, and an Office Memorandum issued by the Department of Personnel and Training.

The Supreme Court's orders from September 6, 2024, and February 20, 2025, specifically delineated how and when enhanced pensions based on notional increments were to be paid, including retrospective application and conditions for different categories of litigants.

The Tribunal reasoned that in contempt jurisdiction, its scope is limited to examining wilful and deliberate disobedience.

It held that a dispute over interpretation, calculation, or consequential benefits, especially when informed by subsequent authoritative pronouncements of the Supreme Court, does not constitute civil contempt.

No material was presented to establish intentional or wilful non-compliance by the respondents.

The Tribunal concluded that the respondents had acted in light of the law laid down and clarified by the Hon'ble Supreme Court and subsequent Government instructions, and no wilful or intentional non-compliance was established.

All pending M.A.s, if any, were also disposed of.

There was no order as to costs.