Contempt proceedings cannot be closed as "substantially complied" without verifying individual consideration of petitioners' cases.

The Petitioners filed a contempt petition (CP No. 663/2023) before the Central Administrative Tribunal (CAT) alleging that the Respondents failed to comply with the directions issued in judgment dated 21 March 2023 in OA 2590/2016

The CAT’s original directions required the Respondents to open sealed covers and consider the Petitioners for promotion to Loco Inspector based on specific footplate experience criteria

On 29 January 2024, the CAT dismissed the contempt petition, holding that a notice issued by Northern Railway on 4 January 2024 constituted "substantial compliance"

The Petitioners challenged this dismissal via the present writ petition, contending the order was mechanical and failed to address whether their specific cases were actually considered

1. Whether the Tribunal was justified in closing the contempt proceedings based solely on a general promotion notice that did not detail the individual consideration of the Petitioners’ cases.

2. Whether the Respondents’ actions constituted "substantial compliance" with the specific directions regarding sealed covers and footplate experience.

The court applied principles governing the exercise of contempt jurisdiction and the necessity of "due consideration" in administrative compliance.

It reinforced that where a judicial direction requires specific actions—such as the opening of sealed covers and re-examination of eligibility based on particular technical criteria (footplate experience)—the mere issuance of a general promotion list does not suffice as evidence of compliance unless it explicitly addresses the status of the affected individuals

The High Court observed that the CAT closed the contempt petition prematurely. It noted that the Northern Railway notice dated 4 January 2024 merely listed promoted individuals but remained silent on whether the Petitioners’ sealed covers were opened or if they were found unfit upon re-examination

The Court reasoned that for the CAT to reach a finding of "substantial compliance," it was obligated to satisfy itself—potentially by calling for the official files—that the Petitioners’ cases were actually processed according to the criteria set in the March 2023 order

The Court found the CAT’s dismissal lacked a factual basis to prove the directions were actually performed regarding the Petitioners

The matter was remanded to the Tribunal (CP 663/2023) for fresh consideration. The Respondents were granted liberty to place further material to prove actual compliance, and the parties were directed to appear before the Tribunal on 8 May 2026. The writ petition was disposed of accordingly.