Correctness of an order passed in compliance with judicial directions cannot be adjudicated in contempt proceedings.

The petitioner, a prematurely retired Chief Medical Officer, filed O.A. No. 181/341/2021 seeking reliefs including subsistence allowance and leave salary for the period between 03.07.2020 and 15.09.2020

The Tribunal allowed the O.A. on 21.03.2025

While other reliefs were settled, the respondents passed an order on 18.04.2025 (Annexure-P2) treating the specified period of absence as dies non (unauthorised absence) and rejecting the claim for medical leave allowance

The respondents challenged the original Tribunal order before the High Court in OP(CAT) 7/2026; however, the High Court dismissed the petition at the admission stage, recording that the respondents had already complied with the Tribunal's directions by passing the order dated 18.04.2025

The petitioner filed this contempt petition alleging that the 18.04.2025 order violated the "true spirit" of the Tribunal's original directions

Whether the issuance of the order dated 18.04.2025, which rejected the petitioner's claim by treating his absence as dies non, constitutes contempt under Section 17 of the Administrative Tribunals Act read with Section 12 of the Contempt of Courts Act

The Tribunal applied Section 17 of the Administrative Tribunals Act, 1985, and Section 12 of the Contempt of Courts Act, 1971, regarding the exercise of contempt jurisdiction

It adhered to the established legal principle that once a subsequent order is passed by an authority in purported compliance with a judicial direction, the "correctness or otherwise" of that new order cannot be scrutinized within the limited scope of contempt proceedings

The Tribunal found that the respondents had taken definitive action by passing the order dated 18.04.2025 (Annexure-P2)

It noted that the High Court had already recognized this order as an act of compliance when dismissing the respondents' original petition

The Tribunal reasoned that the petitioner’s grievance—that the new order did not realize the "true spirit" of the original judgment—pertained to the merits of the decision rather than a total failure to comply

Consequently, the Tribunal determined that it cannot probe into the legality or validity of a fresh order under the guise of contempt; such an order creates a new cause of action that must be challenged through appropriate legal channels

The Tribunal held that the correctness of the Annexure-P2 order cannot be adjudicated in contempt proceedings

The Contempt Petition was closed