Contempt proceedings cannot adjudicate promotion claims beyond the scope of the original litigation.

The applicants instituted contempt petitions alleging non-compliance with directions issued by the Tribunal in the underlying original applications.

The respondents submitted that the Tribunal’s directions had been complied with and filed affidavits confirming such compliance.

The applicants did not dispute the respondents’ assertion that MACP benefits had been considered and granted as admissible under the MACP Scheme.

However, they contended that the respondents ought also to have considered them for promotion because certain juniors had allegedly been promoted during the intervening period.

The applicants’ counsel conceded that the promotion of juniors was not the subject matter of the present litigation.

Whether the contempt petitions should continue when the respondents had complied with the directions issued by the Tribunal and filed affidavits to that effect.

Whether the applicants’ grievance concerning consideration for promotion, including the alleged promotion of juniors, could be adjudicated in the present contempt proceedings.

The Tribunal applied the principle that contempt proceedings are confined to examining compliance with the directions contained in the underlying order and cannot be used to adjudicate a fresh or unrelated substantive claim.

Since the applicants’ claim for promotion and the alleged promotion of their juniors did not form part of the subject matter of the original litigation, that grievance could not be examined in the contempt proceedings.

The respondents asserted, supported by filed affidavits, that they had complied with the Tribunal’s directions, including consideration and grant of admissible MACP benefits.

The applicants did not challenge that assertion but sought to expand the proceedings by raising a claim for promotion based on the alleged promotion of juniors.

Because the applicants themselves acknowledged that this issue was outside the scope of the original litigation, the Tribunal held that the alleged promotion-related grievance could not be examined in the present contempt jurisdiction.

The applicants were therefore left to pursue that grievance separately in accordance with law.

Accordingly, all four contempt petitions were closed, the notices were discharged, and any pending miscellaneous application was disposed of.

The applicants were granted liberty to agitate their surviving grievances, including their claim for promotion, afresh in accordance with law.

No order was made as to costs, and the Registry was directed to place a copy of the common order in the judicial files of all the contempt petitions.