Contempt proceedings cannot examine the authenticity or fabrication of documents supplied in compliance with a court's direction.

The Petitioners, formerly Assistant Programmers on a contract basis with the CBI, were relieved from their services in November 2016.

In a previous Miscellaneous Application (MA 2308/2018), the Central Administrative Tribunal (CAT) directed the Respondents to furnish copies of orders dated 11.11.2016 and 18.11.2016, if they existed.

The Respondents instead provided Office Orders No. 207/2016 and 208/2016 dated 27.12.2016, which recorded that the Petitioners were relieved with effect from (w.e.f.) the respective November dates.

The Petitioners filed a contempt petition (CP 203/2019), alleging that the specific orders of November 2016 were not produced.

The CAT dismissed the contempt petition on 10.01.2020, holding that the order had been substantively complied with.

1. Whether the Respondents committed contempt of the Tribunal’s order dated 25.02.2019 by failing to produce documents specifically dated 11.11.2016 and 18.11.2016.

2. Whether the allegation that the supplied Office Orders were "fabricated" can be adjudicated within the scope of contempt proceedings.

The Court applied the principles governing the exercise of contempt jurisdiction, specifically focusing on the requirement of "substantial compliance."

The court applied the principle that allegations of fraud or "fabrication" of documents are substantive factual disputes that fall outside the limited summary jurisdiction of contempt proceedings.

The Court observed that the CAT’s initial direction was conditional, requiring the Respondents to produce the specific November orders "if such orders are in existence".

Upon review, the Court found that the Respondents never stated on oath that orders dated 11.11.2016 or 18.11.2016 existed; rather, they stated that the Petitioners were relieved on those dates.

The Court concluded that the reference to "orders" dated in November in the CAT’s earlier direction was an inadvertent error, as those were merely the effective dates of termination.

Regarding the Petitioners' claim that the December orders were fabricated, the Court held that such a challenge is a separate cause of action and cannot be examined in a contempt proceeding, which is strictly limited to willful disobedience of a specific judicial direction.

The Court held that the Respondents provided the relevant relieving orders, satisfying the substance of the Tribunal's direction.

The Writ Petition was dismissed, and the orders of the CAT were upheld.