Disputed legal heirship and policy-driven impracticability negate wilful disobedience in contempt proceedings.

The applicant, Jai Kishan Gupta, filed a contempt petition alleging non-compliance with the Tribunal's order dated 11.10.2018

The original litigation (O.A. No. 1013/2006) was filed by 26 commission vendors challenging their retirement; the Tribunal had directed that the applicants or their legal heirs interested in performing duties as commission vendors be allowed to continue as per existing Railway Board policy

One of the original applicants, Kishan Lal (Applicant No. 24), died on 19.07.2015 during the pendency of the O.A.

No substitution application was filed for Kishan Lal before the Tribunal, the High Court, or the Supreme Court, despite the order being affirmed by both higher courts by 17.12.2024

The petitioner claimed to be Kishan Lal's legal heir based on an unprobated Will dated 06.08.2012

The respondents contended that the O.A. abated regarding Kishan Lal in 2015

the Will was invalid/disputed, and subsequent changes in the Catering Policy (2017/2019) had permanently closed departmental catering units, making the order impossible to implement

1. Whether the respondents committed "wilful and deliberate disobedience" of the order dated 11.10.2018 by not engaging the legal heir of a deceased applicant

2. Whether the validity of an unprobated Will and the status of a legal heir can be adjudicated within the limited scope of contempt jurisdiction

3. Whether subsequent policy changes rendering the implementation of a court order "impracticable" constitute a valid defense against a contempt charge

The court primarily applied the principles governing the scope of contempt jurisdiction, emphasizing that it is limited to determining whether there has been "wilful and deliberate disobedience"

It relied on the precedent of Prithawi Nath Ram v. State of Jharkhand (2004) 7 SCC 261, which established that a contempt court cannot go behind the original order, examine its correctness, or adjudicate fresh disputes or determine rights requiring detailed examination of facts and evidence

The court also noted the principle that if a party dies and no substitution is filed within the prescribed time, the proceedings abate by operation of law

The Tribunal observed that since Kishan Lal died in 2015 and no substitution occurred, the O.A. technically abated regarding him

The applicant's claim as a legal heir is based on an unprobated Will, the genuineness and validity of which are strictly disputed by the respondents

The Tribunal reasoned that determining the authenticity of the Will or the applicant's status as a legal heir involves a trial on facts, which exceeds the summary nature of contempt proceedings

Furthermore, the respondents demonstrated that the Railway Board's Catering Policy 2017 and subsequent orders in 2019 discontinued departmental catering and commission vendors

The Tribunal found that the complexity arising from the disputed heirship combined with these intervening policy changes meant that the failure to comply did not stem from a "wilful" or "deliberate" intent to flout the court's authority

It ruled that contempt jurisdiction cannot be used to resolve substantive disputes regarding legal heirship or to enforce rights that require fresh adjudication in light of new policy frameworks

Consequently, the contempt petition was closed and consigned to record

All pending Miscellaneous Applications were disposed of accordingly