Contempt proceedings must be closed upon substantial compliance; executing courts cannot go behind the original order.

The applicant, a retired Senior Accountant, filed O.A. No. 1098/2023 seeking a notional increment.

On 05.08.2024, the Tribunal partly allowed the O.A., directing the respondents to issue a revised Pension Payment Order (PPO) and pay arrears for three years preceding the filing date (15.12.2023) within four months.

Following the applicant’s death, his legal heirs pursued the matter.

The respondents filed a compliance affidavit on 19.03.2025, asserting that the PPO had been revised and the notional increment granted.

The applicants filed objections, contending that the respondents restricted arrears to 01.05.2023 instead of 15.12.2020, thereby violating the specific directions of the Tribunal and wrongly relying on unrelated Supreme Court interim orders despite the dismissal of the respondents' Review Application on 10.09.2025.

1. Whether the respondents committed willful and contumacious disobedience of the Tribunal’s order dated 05.08.2024 by allegedly miscalculating the period of arrears.

2. Whether the revision of the PPO and grant of notional increment constitutes "substantial compliance" sufficient to discharge contempt notices.

The Tribunal exercised its jurisdiction under Section 17 of the Administrative Tribunals Act, 1985, which empowers it to punish for contempt.

It applied the established legal principle that an executing court or a court in contempt proceedings cannot go behind the original order that is alleged to have been violated.

The court further relied on the doctrine of "substantial compliance," wherein the fulfillment of the core directions of a judgment warrants the closure of contempt proceedings.

The Tribunal examined the respondents’ compliance affidavit and the letter dated 12.03.2025, which confirmed the revision of the applicant's PPO and the grant of one notional increment.

Regarding the applicant’s objection that the arrears were restricted to a shorter duration than ordered, the Tribunal noted that such disputes over exact calculations or interpretations of the original order cannot be adjudicated within the narrow scope of contempt jurisdiction.

Since the primary mandate—the revision of the PPO and the grant of the benefit—was executed, the Tribunal reasoned that "substantial compliance" had been achieved.

It concluded that it was not permissible to re-examine the merits or details of the underlying order once the main direction had been implemented.

Consequently, the contempt proceedings were closed, the notices issued to the respondents were discharged, and all associated Miscellaneous Applications (MAs) were disposed of.