Substantial compliance, absent wilful disobedience, warranted closure of contempt proceedings.

In O.A. No. 1323/2019, the Tribunal directed the respondents to pay the applicant’s pension and other post-retirement benefits, with interest at 6% per annum from the dates the amounts became due, within three months of receiving the certified order

In the contempt proceedings, the respondents stated that they had issued a Pension Payment Order and sanctioned and paid DCRG of ₹2,37,380; a speaking order also recorded that 6% interest was payable

The applicant disputed full compliance, alleging that leave encashment, pension arrears from 1 July 2018 to September 2024, and other terminal dues remained unpaid

Whether the respondents wilfully or deliberately disobeyed the Tribunal’s order dated 10 April 2023

Whether the compliance shown by the respondents was sufficient to close the contempt proceedings despite the applicant’s objections concerning unpaid dues

Section 17 of the Administrative Tribunals Act, 1985, provides the Tribunal’s jurisdiction in contempt proceedings

The Tribunal applied the principle that contempt requires a finding of wilful or deliberate disobedience of its order; substantial compliance with the operative directions may negate such a finding

The underlying order required payment of pension and other post-retirement benefits with 6% annual interest from the dates the amounts became due

The Tribunal considered the respondents’ affidavits and the speaking order recording the sanction and payment of DCRG, issuance of the PPO, and the direction to pay interest at 6%

Although the applicant alleged that several dues remained unpaid and challenged the completeness of the compliance evidence, the Tribunal concluded that the respondents had substantially complied with the original order.

It therefore found insufficient grounds to hold that they had acted wilfully or deliberately in disobedience of that order

It closed the contempt proceedings, consigned the matter to the records, discharged any notices issued to the respondents, and disposed of any pending miscellaneous application accordingly