Scope of Contempt Jurisdiction Excludes Adjudication on Correctness or Adequacy of Compliance Orders

The applicant filed a Contempt Petition alleging wilful disobedience of the Tribunal’s order in O.A. No. 1635/2019. The original O.A. was allowed following a batch of cases (O.A. No. 2756/2019), where similarly situated employees were granted benefits from the date of their termination.

The respondents issued a compliance order (Corrigendum-I dated 24.03.2026) but granted the applicant benefits prospectively ("with immediate effect") rather than from the date of termination.

The applicant argued this constituted discrimination and non-compliance.

The respondents contended that a reasoned speaking order had been passed and no wilful disobedience existed.

1. Whether the grant of prospective benefits instead of retrospective benefits (from the date of termination) amounts to wilful disobedience of the Tribunal's order under contempt jurisdiction.

2. Whether the merits or adequacy of a compliance order can be adjudicated within a Contempt Petition.

The court applied the principle that the scope of contempt jurisdiction is strictly limited to examining whether there is "wilful and deliberate disobedience" of a court's direction.

It relied on the doctrine that once a compliance order or a reasoned speaking order is passed, any grievance regarding the correctness, adequacy, or extent of the relief granted falls outside the ambit of contempt proceedings and requires substantive adjudication through fresh legal proceedings.

The Tribunal examined whether the respondents' actions met the threshold of deliberate defiance. It noted that the respondents had indeed acted by passing a compliance order on 24.03.2026.

While the applicant argued that the relief was insufficient and discriminatory compared to the "batch matters," the Tribunal reasoned that such a dispute pertains to the "correctness and adequacy" of the implementation.

The court held that determining whether the applicant is entitled to identical retrospective relief as others requires a substantive merit-based review, which cannot be performed in a contempt proceeding.

Since an order of compliance existed, the "wilful" element of disobedience could not be established.

The Contempt Petition was closed, and notices to the alleged contemnors were discharged. The applicant was granted liberty to challenge the adequacy of the compliance order through appropriate legal remedies. No costs were awarded.