CAT - Allahabad

Payment of principal arrears without awarded interest constitutes incomplete compliance with judicial directions.

D K PATHAK vs SATISH KUMAR, CHAIRMAN, RAILWAY BOARD, MINISTRY OF RAILWAY, RAIL BHAWAN, NEW DELHI.

CAT - AllahabadJUDGMENT: April 08, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners sought the implementation of the Tribunal’s order dated 13.10.2023, which directed the Railway Board to allow the petitioners to opt for their parent cadre (Northern Railway) and granted them proforma promotions w.e.f. 01.11.2003 with all consequential benefits and 6% simple interest per annum

Source reference: p. 2

Following a modification application (MA No. 3912/2023) necessitated by the retirement of two petitioners and the death of the third, the Tribunal modified the order on 15.01.2024 to grant these benefits notionally

Source reference: p. 2

The respondents challenged the order via a Writ Petition in the High Court, which is currently pending

Source reference: p. 3

In a compliance affidavit dated 26.11.2025, the respondents claimed that settlement dues had been paid and the order was fully complied with

Source reference: p. 3

The petitioners, however, argued that while principal payments were received, the 6% simple interest mandated by the Tribunal remained unpaid

Source reference: p. 3
02

Issues

1. Whether the respondents have achieved full compliance with the Tribunal’s directions, specifically regarding the payment of 6% simple interest on arrears

Source reference: p. 3

2. Whether the personal appearance of the competent authority is warranted due to the alleged non-compliance with the interest component of the order

Source reference: p. 3-4
03

Law Applied

The court applied the principles of the Contempt of Courts Act, 1971, regarding the willful disobedience of judicial mandates.

Source reference: p. 2, 3

It emphasized that "consequential benefits" and specific directions for "simple interest" must be satisfied to constitute full compliance

Source reference: p. 2, 3

The court further relied on procedural law governing the filing of a "better compliance affidavit" when a respondent's claim of fulfillment is contested by the petitioner based on specific omitted reliefs

Source reference: p. 3
04

Reasoning

The Tribunal scrutinized the rival submissions and the modification order dated 15.01.2024, noting that the direction for 6% simple interest remained an integral part of the final order

Source reference: p. 3

The court observed that while the respondents demonstrated the payment of settlement dues through letters dated 17.07.2025, 18.07.2025, and 12.08.2025, they failed to provide evidence of the interest payment

Source reference: p. 3

The Tribunal reasoned that partial payment of dues does not equate to full compliance when a specific interest rate is ordered.

Source reference: p. 3

Therefore, the respondents were found to be in continuing default of the specific direction regarding the interest component

Source reference: p. 3
05

Holding

The Tribunal held that the respondents had not fully complied with the order as the 6% interest remained unpaid

It directed the respondents to comply with the interest direction and file a "better compliance affidavit"

Source reference: p. 3

The court ordered that if the direction is not satisfied by the next hearing on 07.05.2026, the competent authority among the respondents must appear in person or via video conferencing to explain the non-compliance

Source reference: p. 4
CAT - Allahabad

Original Court PDF

D K PATHAKvsSATISH KUMAR, CHAIRMAN, RAILWAY BOARD, MINISTRY OF RAILWAY, RAIL BHAWAN, NEW DELHI.

CAT - Allahabad · April 08, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment