Contempt proceedings may be dropped upon compliance without determining guilt or exoneration.

The petitioner initiated contempt proceedings alleging non-compliance with the Tribunal’s order in O.A. No. 050/00599/2024.

At the hearing, the petitioner’s counsel stated that the directions had been complied with, and the respondents’ counsel confirmed compliance.

The Tribunal therefore recorded that no grievance concerning implementation remained.

Whether the contempt petition should be brought to an end after the parties confirmed compliance with the order under contempt.

Whether the proceeding needed to remain pending for placement before a Bench of at least two Members under Rule 6 of the CAT (Contempt of Courts) Rules, 1992, where no further contempt proceeding was considered necessary.

The Tribunal noted that contempt jurisdiction is directed to securing compliance with its orders, as reflected in Section 27 of the Administrative Tribunals Act, 1985, and to addressing disobedience of those orders.

Rule 6 of the CAT (Contempt of Courts) Rules, 1992 ordinarily requires contempt proceedings to be dealt with by a Bench of not less than two Members, subject to the stated exception for contempt in a Member’s view or presence.

The Tribunal also referred to Rule 24 of the CAT (Procedure) Rules, 1987, which empowers it to make orders or give directions necessary or expedient to give effect to its orders, prevent abuse of process, or secure the ends of justice.

It further cited a Supreme Court order dated 14 February 2025 in Tirthankar Basu & Ors. v. Nivedita Shukla Verma & Ors. (case number as stated in the judgment), where contempt proceedings were closed after compliance and no useful purpose would be served by keeping them pending.

The Tribunal relied on both sides’ confirmation that the underlying directions had been complied with and found that no implementation grievance survived.

It reasoned that keeping the petition pending solely to place it before a two-Member Bench would unnecessarily prolong the process when no further proceeding was required.

Accordingly, it confined its order to recording compliance and expressly made no finding on willful disobedience, guilt, or exoneration.

It dropped the contempt petition as unnecessary and discharged the notices, without adjudicating any allegation of willful disobedience; there was no order as to costs.