Merits of a speaking order passed in compliance cannot be adjudicated in contempt jurisdiction.

The petitioner, a senior citizen and former railway employee, filed a contempt petition alleging non-compliance with the Tribunal's order dated May 27, 2025

In the original proceedings (OA No. 452/2025), the Tribunal had directed the competent authority to decide the petitioner's representation dated May 30, 2024, through a reasoned and speaking order within three months

The petitioner contended that the direction was not followed in its true letter and spirit

Conversely, the respondents filed a compliance affidavit asserting that a reasoned and speaking order was passed on March 02, 2026, and duly communicated to the petitioner

1. Whether the respondents’ actions constituted "wilful or deliberate disobedience" of the Tribunal’s directions sufficient to sustain contempt proceedings

2. Whether the Tribunal, in exercising its contempt jurisdiction, can adjudicate upon the merits or correctness of a speaking order passed in purported compliance with its directions

The Tribunal applied the principles governing contempt jurisdiction, emphasizing that it has a limited scope to examine only whether directions have been complied with, not the merits of the resulting decision

It relied on the landmark precedent of J.S. Parihar v. Ganpat Duggar, which established that once an order is passed in purported compliance of a court's directions, the merits of that order cannot be examined in contempt proceedings

Furthermore, it applied the principle from Rama Narang v. Ramesh Narang (2021), which mandates that the power to punish for contempt must be exercised with caution and only in cases of clear and wilful disobedience

The Tribunal examined whether the "limited scope" of its direction—to decide the representation—had been met

It observed that the respondents produced a speaking order dated March 02, 2026, which addressed the petitioner’s representation

The Tribunal reasoned that once a decision is taken and communicated, the cause for invoking contempt jurisdiction ceases to exist, as the specific direction of the court stands complied with

The court noted that any grievance regarding the correctness of the respondents' decision constitutes a fresh cause of action and cannot be adjudicated within the narrow confines of contempt law, as no "wilful" or "deliberate" defiance was evident

The contempt proceedings were dropped, and the notices issued to the respondents were discharged

However, the Tribunal granted the petitioner liberty to avail appropriate legal remedies to challenge the merits of the speaking order dated March 02, 2026, if still aggrieved

No order as to costs was made