CAT - ['Delhi']

Release of Withheld Arrears and Payment to Legal Heirs Constitutes Substantial Compliance in Contempt Proceedings

Naresh Kumar vs MS VANDITA KAUL & ORS

CAT - ['Delhi']JUDGMENT: May 12, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Six retired postal employees (petitioners) filed a Contempt Petition alleging non-compliance with the Tribunal's directions regarding the revision of Modified Assured Career Progression (MACP) dates and subsequent arrears

Source reference: p. 1-2

Earlier, on 13.02.2026, the respondents filed a compliance affidavit stating they had paid arrears but withheld 15% of the total amount pending verification by the Accounts Authorities

Source reference: p. 3, para. 6

In the case of Petitioner No. 2, Sh. Sunil Kumar Jain (deceased), payments were pending claim submission by legal heirs

Source reference: p. 3

On 08.04.2026, the Tribunal noted that the withheld 15% remained unpaid and granted a final opportunity for compliance

Source reference: p. 3-4
02

Issues

1. Whether the respondents willfully disobeyed the Tribunal's directions by withholding 15% of the arrears and failing to release dues to the legal heirs of the deceased petitioner

Source reference: p. 3, para. 1-2

2. Whether the subsequent actions taken by the respondents constitute "full compliance" warranting the discharge of contempt notices

Source reference: p. 4, para. 3
03

Law Applied

The court applied the principles governing Contempt of Court under the Contempt of Courts Act, 1971, specifically focusing on whether there was "substantial compliance" with judicial orders.

Source reference: no citation

The court relied on the administrative procedure for MACP revision and pensionary benefits, including the requirement of verification by the General Manager (Finance) and Postal Accounts departments

Source reference: p. 3, para 6

It followed the principle that once the core grievance (payment of arrears) is redressed and the judicial direction is implemented in letter and spirit, the contempt proceedings may be closed

Source reference: p. 4-5
04

Reasoning

The court evaluated the respondents' fresh compliance affidavit filed on 12.05.2026. The respondents demonstrated that the previously withheld 15% of arrears, which was pending verification by the concerned Accounts Authorities, had now been fully released to all six petitioners

Source reference: p. 4, para. 5

Specifically, the court noted that the respondents provided proof of payment for all individuals, ranging from approximately ₹41,377 to ₹1,15,514

Source reference: p. 4

Regarding the deceased Petitioner No. 2, the court observed that the benefits were successfully released to his legal heir, Mrs. Chhavi Jain, via payment on 28.04.2026

Source reference: p. 4

By presenting specific payment figures and Annexure CPR/1 (payment proofs), the respondents neutralized the claim of "willful disobedience"

Source reference: p. 4-5
05

Holding

The Tribunal held that the directions had been fully complied with by the respondents

The Contempt Petition (C.P. No. 663/2025) was closed and the notices issued to the contemnors were discharged. However, the court granted the petitioners liberty to seek further legal recourse if any lingering grievances remained regarding the calculations or implementation

Source reference: p. 5, para. 3
CAT - ['Delhi']

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Naresh KumarvsMS VANDITA KAUL & ORS

CAT - ['Delhi'] · May 12, 2026

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