Contempt requires wilful disobedience; swift compliance is not contemptuous.

The petitioner, Vishnu Gouda, filed a contempt petition alleging willful disobedience of an order dated January 29, 2026, issued by the Tribunal in OA No. 52/2026

In OA No. 52/2026, the Tribunal had directed Respondent No. 1 to consider the petitioner's representations dated January 16, 2026, and January 23, 2026, taking into account representations from Respondent No. 4 and observations/directions from OA No. 42/2026

The order also stipulated that the petitioner should be permitted to work at his original place of transfer until a decision was made on the representations

The respondents filed a reply affidavit, including copies of an order dated January 30, 2026, passed by the competent authority in compliance with the directions in OA No. 52/2026, and a compliance order dated January 30, 2026, in OA No. 42/2026

The petitioner argued that the immediate compliance on January 30, 2026, not allowing him to continue at Mysuru while allowing Respondent No. 4 to continue at BNC for 10 days, and the transfer of another officer to Mysuru on January 29, 2026, demonstrated contemptuous action

Whether the respondents' actions constituted a breach and willful disobedience of the Tribunal's order dated January 29, 2026, in OA No. 52/2026

The court primarily applied the principles governing contempt of court, which require a finding of "wilful disobedience or breach" of a court order

The judgment implicitly referenced the requirement that compliance with earlier orders must not only occur but also demonstrate a genuine consideration of the directions, rather than a mere procedural formality, to avoid being deemed contemptuous

The Tribunal considered the petitioner’s argument that swift compliance alone, especially when contrasted with the situation of another party (Respondent No. 4), suggested a "hasty manner" and "contemptuous" action

However, the Tribunal reviewed the compliance order dated January 30, 2026, submitted by the respondents

The court found that merely because compliance with its directions in OA No. 52/2026 occurred swiftly did not, by itself, constitute contemptuous action

The court noted that the respondents had placed on record the compliance order.

The analysis focused on whether there was deliberate non-compliance rather than the speed of compliance

As a result, no further proceedings were warranted

The Contempt Petition was dismissed, and notices were discharged