CAT - Allahabad

Contempt proceedings closed upon full compliance with directions for retrospective promotion and consequential benefits.

Vivek Balwant Rao Umap vs SR S K KOHLI SECRETARY DEFENCE SERVICES

CAT - AllahabadJUDGMENT: March 27, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner filed this contempt petition alleging non-compliance with the Tribunal’s order dated 16.11.2017 in OA No. 397 of 2012

Source reference: p. 2

The original order quashed a 2011 decision and directed the respondents to hold a Review DPC for the petitioner’s promotion to the Junior Administrative Grade (JAG) and subsequently for the Non-Functional Selection Grade (NFSG), citing that his juniors had been promoted and his penalty period had expired

Source reference: p. 2

A Review Application (No. 03 of 2018) filed against this order was dismissed on 14.02.2018

Source reference: p. 2

Between 2018 and 2024, the respondents filed multiple compliance affidavits

Source reference: p. 2

On 09.12.2024, the respondents filed a final compliance affidavit in MA No. 6264 of 2024, asserting that the directions had been fully executed

Source reference: p. 2

The petitioner failed to file objections or appear for the final hearing

Source reference: p. 2
02

Issues

1. Whether the respondents willfully disobeyed the directions of the Tribunal dated 16.11.2017 regarding the holding of a Review DPC and grant of consequential benefits

Source reference: p. 2

2. Whether the administrative order dated 23.09.2024 issued by the Controller General of Defence Accounts constitutes full compliance with the Tribunal’s mandate

Source reference: p. 3-4
03

Law Applied

The Tribunal applied the principles of civil contempt regarding the "willful disobedience" of judicial orders

Source reference: no citation

It further relied on the administrative guidelines governing the Indian Defence Accounts Service (IDAS), specifically the procedures for placement in the Non-Functional Selection Grade (NFSG) based on the recommendations of a Screening Committee

Source reference: p. 3
04

Reasoning

The Tribunal examined the evidence of compliance submitted by the respondents, specifically focusing on the order dated 23.09.2024 issued by the Office of the Controller General of Defence Accounts

Source reference: p. 3

This order confirmed that the Competent Authority approved the placement of the petitioner in the NFSG of the Junior Administrative Grade of IDAS with retrospective effect from 01.01.2010, following a Screening Committee meeting held on 11.07.2024

Source reference: p. 3

The Tribunal noted that this order superseded previous promotion orders and initiated the process for pay fixation

Source reference: p. 3

The court observed that despite various opportunities and the absence of the petitioner’s counsel, the documentary evidence—specifically the retrospective promotion and the direction for consequential pay fixation—demonstrated that the respondents had substantially fulfilled the requirements of the original order dated 16.11.2017

Source reference: p. 4
05

Holding

The Tribunal held that the order dated 16.11.2017 had been fully complied with by the respondents

Accordingly, the contempt proceedings were closed, and the notices issued to the respondents were discharged

Source reference: p. 4

All associated Miscellaneous Applications were disposed of

Source reference: p. 4
CAT - Allahabad

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Vivek Balwant Rao UmapvsSR S K KOHLI SECRETARY DEFENCE SERVICES

CAT - Allahabad · March 27, 2026

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