CAT - ['Delhi']
Employment and Labour LawAdministrative and Public Law

Regularisation must be followed by consequential benefits in accordance with the governing judgment.

Ritika Arora vs SHRI KESHAV CHANDRA & ANR

CAT - ['Delhi']JUDGMENT: September 08, 20262 MIN READSOURCE JUDGMENT
Regularisation must be followed by consequential benefits in accordance with the governing judgment.. Ritika Arora vs SHRI KESHAV CHANDRA & ANR. CAT - ['Delhi']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The 21 applicants, working as Auxiliary Nurse Midwives (ANMs) with the NDMC, initiated contempt proceedings alleging incomplete compliance with the Tribunal’s directions and the consequential judgment of the High Court.

Source reference: para. 1

The respondents had issued Office Order dated 25 August 2026 regularising the applicants’ services, but the regularisation was stated to operate only from the date of the High Court’s judgment.

Source reference: para. 2; p. 4; para. 6; p. 5

The applicants contended that, having worked for approximately 20 years, they were entitled not only to regularisation but also to consequential benefits, including pay fixation, seniority and continuity of service from the date of initial appointment, without back wages.

Source reference: para. 1; p. 4; paras. 2–5; pp. 4–5

The respondents submitted that the consequential benefits would be released in due course.

Source reference: para. 6; p. 5
02

Issues

Whether regularisation of the applicants’ services from the date of the High Court’s judgment constituted complete compliance with the Tribunal’s and High Court’s directions, or whether the applicants were additionally entitled to consequential benefits from the date of their initial appointment?

Source reference: paras. 2–5; pp. 4–5

Whether the contempt petition should continue in view of the respondents’ assurance that the consequential benefits would be released in due course?

Source reference: paras. 6–10; pp. 5–6
03

Law Applied

The Tribunal relied upon the High Court’s decision in Pawan Sharma & Ors. v. GNCTD & Ors., W.P.(C) No. 2117/2025, which directed regularisation against the posts to which the employees were originally appointed, irrespective of the nomenclature of their appointments, with pay fixation by treating them as regularly appointed ab initio and grant of consequential benefits, but without back wages.

Source reference: para. 3; p. 4

It further relied upon NDMC & Ors. v. Kalpana Sharma & Ors., W.P.(C) No. 4646/2026, wherein similarly situated employees were held entitled to fixation of pay, seniority and continuity of service from the date of initial appointment, without back wages.

Source reference: para. 4; p. 5

The applicable contempt principle was that contempt proceedings would not warrant further action where the alleged contemnor had undertaken to comply with the operative directions and the remaining benefits were to be extended expeditiously in accordance with law.

Source reference: paras. 8–10; p. 6
04

Reasoning

The Tribunal accepted that mere regularisation from the date of the High Court’s judgment did not, by itself, resolve the applicants’ claim for consequential benefits under the applicable High Court judgments.

Source reference: paras. 2–5; pp. 4–5

However, the respondents expressly stated that the consequential benefits, in terms of the Tribunal’s directions read with the High Court’s judgment, would be released in due course.

Source reference: para. 6; p. 5

On that assurance, the Tribunal considered that the respondents were expected to take the necessary steps and extend the benefits expeditiously and in accordance with law.

Source reference: para. 8; p. 6

Since no further adjudication was considered necessary at that stage, the contempt proceedings were closed.

Source reference: paras. 9–10; p. 6
05

Holding

The Tribunal did not finally determine the applicants’ entitlement to each consequential benefit but recorded the respondents’ undertaking to release such benefits in accordance with the Tribunal’s directions and the High Court judgments.

Holding that nothing further survived for consideration at that stage, it closed Contempt Petition No. 251/2026 and discharged the notices, if any.

Source reference: paras. 9–10; p. 6
CAT - ['Delhi']

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Ritika AroravsSHRI KESHAV CHANDRA & ANR

CAT - ['Delhi'] · September 08, 2026

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