Contempt proceedings do not survive for adjudication following the recall of the underlying review order.

The petitioners, comprising nine retired and serving Stenographers and Reporters from Doordarshan Kendra and Akashvani, filed a contempt petition against officials of the Ministry of Information and Broadcasting and Prasar Bharati for alleged non-compliance with orders passed in OA No. 1431/2023.

During the pendency of the contempt proceedings, a subsequent legal development occurred wherein the Tribunal recalled an order of review associated with the original application.

Consequently, the counsel for the applicant submitted that the grounds for the contempt petition no longer existed for adjudication.

Whether the contempt petition survives for adjudication following the recall of the review order by the Tribunal.

The Tribunal applied the principle of procedural infructuousness in contempt jurisdiction.

Contempt proceedings are maintainable only so long as there is a valid, subsisting order to be enforced; if the underlying order or a relevant review order is recalled or modified by the court such that the basis of the grievance is removed, the contempt petition ceases to survive for adjudication.

The Tribunal’s reasoning was based on the submission made by the applicant's counsel regarding the "subsequent development" in the litigation history of the case.

Since the Tribunal had recalled the order of review, the legal foundation upon which the contempt petition was likely predicated had been altered or removed.

The court accepted the advocate's contention that the matter did not survive for further judicial scrutiny, as the specific legal circumstances necessitating the contempt action had been rendered moot by the Tribunal's own subsequent action of recalling the review.

The Contempt Petition was disposed of, and the notices previously issued to the alleged contemnors were discharged.