Section 21 of the Administrative Tribunals Act applies to contempt proceedings; recurring cause of action negates limitation.

The applicant, a retired Safaiwala, originally filed OA 107/2014 challenging a penalty order.

On 06.11.2023, the Tribunal quashed the penalty to the extent that it would not adversely affect her pension.

Alleging non-compliance, the applicant filed a Contempt Petition (CP) on 25.08.2025.

Simultaneously, the applicant filed MA 217/2025 seeking condonation of delay in filing the CP.

The respondent-Railways objected, arguing the CP was barred by the one-year limitation period prescribed under Section 20 of the Contempt of Courts Act, 1971, citing Pallav Sheth v. Custodian.

1. Whether the limitation provisions for contempt proceedings in the Tribunal are strictly governed by Section 20 of the Contempt of Courts Act or can be read with Section 21 of the Administrative Tribunals Act, 1985.

2. Whether the continuous non-payment of pension in accordance with a judicial direction constitutes a "recurring cause of action" for the purpose of limitation.

The court applied Rule 22 of the CAT (Contempt of Courts) Rules, 1992, which permits the application of the Tribunal's general procedural rules to contempt matters.

It relied on Section 21 of the Administrative Tribunals Act (ATA), 1985, which grants the Tribunal power to condone delay if "sufficient cause" is shown.

While acknowledging Section 20 of the Contempt of Courts Act, 1971—which generally bars initiation of contempt after one year from the date of the alleged act—the court applied the doctrine of "recurring cause of action" for continuous disobedience.

The Tribunal reasoned that since the CAT Contempt Rules do not specifically provide a limitation period, Section 21 of the ATA applies mutatis mutandis, granting the bench discretionary power to admit petitions beyond one year upon satisfaction of sufficient cause.

The Bench observed that as no specific timeframe was set in the original order dated 06.11.2023, the respondents were expected to comply within a reasonable period; thus, there was no undue delay.

Furthermore, the court held that the non-payment of pension in terms of the judicial order is a continuing wrong, creating a recurring cause of action that prevents the petition from being barred by the one-year limit under Section 20 of the Contempt of Courts Act.

The precedents cited by the respondents (Pallav Sheth and Maheshwar Peri) were held not to debar the Tribunal from entertaining the petition in these circumstances.

It held that the CP was maintainable either because the delay was condonable under Section 21 ATA or because the nature of the breach (pension) constituted a recurring cause of action.

The Tribunal granted the respondents three months to comply with the order dated 06.11.2023, failing which the erring officers would face contempt proceedings. The matter was listed for 25.05.2026.