Correctness of implementation of court directions constitutes a fresh cause of action beyond the scope of contempt jurisdiction.

The petitioners filed a Contempt Petition (CP No. 706/2023) alleging non-compliance with the Tribunal's directions regarding the grant of benefits under the ACP/MACP Scheme

The respondents filed a compliance affidavit on 13.11.2025, stating that the competent authority had approved the grant of benefits via an Office Memorandum dated 22.07.2025

Consequently, arrears were paid to the petitioners

However, the petitioners’ counsel argued that while the benefits were granted, the respondents failed to fix the pay in the correct scale of Rs. 15,600–39,100 with a Grade Pay (GP) of Rs. 5,400, allegedly due to an internal audit communication dated 09.09.2025

Whether the correctness of pay scale calculation and fixation under the ACP/MACP Scheme can be examined by the Tribunal in the exercise of its contempt jurisdiction once substantial compliance through the grant of benefits has been effected

The Tribunal applied the principle of limited jurisdiction in contempt proceedings as established by the Supreme Court in J.S. Parihar v. Ganpat Duggar and others (1996) 6 SCC 291

The rule dictates that once the government passes an order to implement court directions, any dissatisfaction regarding the correctness or merits of that implementation (such as seniority lists or pay fixation) constitutes a fresh cause of action

Such merits cannot be adjudicated under Section 12 of the Contempt of Courts Act, as the court's jurisdiction is confined to determining whether there was willful disobedience of the original order

The Tribunal observed that the respondents had taken positive steps to implement the order, including obtaining competent authority approval and releasing financial arrears

The core of the petitioners' current grievance was not a total failure to comply, but rather the "correctness" of the specific pay fixation and the resulting scale

Relying on the J.S. Parihar precedent, the Tribunal reasoned that if a fresh order or calculation is made in purported compliance with a judicial direction, any error in that calculation—whether right or wrong—gives rise to a new legal grievance

Redrawing scales or re-evaluating the merits of administrative pay fixation would exceed the scope of contempt jurisdiction, which is not an appellate or merit-based review of the compliance order itself

The Contempt Petition (CP) was closed, and the notices issued to the respondents were discharged

The Tribunal granted the petitioners liberty to agitate their specific grievances regarding pay scale fixation through fresh legal proceedings

All associated Miscellaneous Applications (MAs) were disposed of accordingly