Contempt proceedings cannot enlarge the scope of relief granted in the original judgment.

The applicant, V.S. Shah, filed a contempt petition under Section 17 of the Administrative Tribunals Act, 1985, alleging non-compliance with the Tribunal’s order dated 1 November 2023 in O.A. No. 275/2013.

By that order, the Tribunal had set aside the punishment orders dated 17 June 2008 and 25 September 2012 and directed that the applicant be granted all consequential benefits with 6% interest within four months of communication of the certified copy of the order.

During the contempt proceedings, several compliance affidavits were filed by the respondents and objections were filed by the applicant.

On 21 May 2026, the applicant disputed the arrears calculation, particularly because the salary entry for 2007–08 showed a zero figure.

The applicant thereafter sought, inter alia, revision of his basic pay from 1 January 2006, fresh year-wise calculations from 2004 incorporating MACP benefits, employer CPF contributions with interest, recalculation of 6% interest, and inclusion of the alleged omitted due-drawn period from March 2006 to June 2008.

Whether the respondents had failed to comply with the Tribunal’s order dated 1 November 2023 granting the applicant consequential benefits with 6% interest.

Whether the applicant’s additional claims concerning revision of pay from 1 January 2006, MACP benefits, recalculation of CPF and interest, and reopening of the period from March 2006 to June 2008 could be adjudicated in the contempt proceedings.

The Tribunal applied Section 17 of the Administrative Tribunals Act, 1985, which confers contempt jurisdiction upon the Tribunal in matters involving disobedience of its orders.

The operative rule derived from the original order was that, after the punishment orders dated 17 June 2008 and 25 September 2012 were set aside, the applicant was entitled to consequential service and monetary benefits, together with 6% interest, within the prescribed period.

The Tribunal also applied the principle that contempt proceedings are concerned with examining compliance with the existing judicial direction and cannot be used to enlarge, modify, or introduce reliefs beyond the scope of the original order.

The Tribunal examined the respondents’ order dated 10 August 2026 and found that the respondents had restored the applicant’s pay and service position from the date on which the penalty operated, calculated the admissible arrears, deposited the employer’s CPF contribution wherever due, and paid interest at 6% pursuant to the original order.

The applicant’s further demands—particularly revision of basic pay from 1 January 2006, MACP benefits, and reopening of the period from March 2006 to June 2008—were treated as claims seeking relief beyond the scope of the original application and the order dated 1 November 2023.

The Tribunal therefore held that these matters could not establish non-compliance with the operative directions in the original order.

The contempt petition was accordingly closed and consigned to the record; the notices issued to the respondents were discharged, and any pending miscellaneous applications were disposed of.