Substantial compliance with directions to furnish Provident Fund statements necessitates closure of contempt proceedings.

The petitioner, S. Ulaganathan, filed a contempt petition under Section 11 of the Contempt of Courts Act against officials of N.L.C. Limited and the Assistant PF Commissioner (EPFO).

The petitioner alleged that the respondents failed to implement the High Court’s order dated 24.11.2022 in W.P.No.33477 of 2016 which directed N.L.C. to verify records of the petitioner’s engagement and furnish available PF statements, while granting the petitioner liberty to approach the PF authorities (Respondent 3) for further details.

The 3rd Respondent subsequently filed a counter-affidavit detailing the steps taken to comply with the directive.

1. Whether the respondents willfully disobeyed the directions of the Court issued in W.P.No.33477 of 2016 regarding the furnishing of Provident Fund statements and records.

The court exercised its jurisdiction under Section 11 of the Contempt of Courts Act, 1971, which empowers the High Court to punish for contempt of itself.

Contempt proceedings are intended to ensure the majesty of the law and the implementation of judicial orders; however, if the substance of the direction has been complied with during the pendency of the petition, the grievance is deemed redressed.

The Court examined the counter-affidavit filed by the 3rd Respondent (Assistant PF Commissioner) noting that after initial administrative delays regarding the availability of representations, the EPFO obtained the necessary documents and forwarded the available details of EPF Account No. CB/TRY/43768/1228 to the petitioner on 13.05.2025 and to his counsel on 16.05.2025.

The court noted that specific details—including the member's name, joining date (01.08.1999), and current balances (Employee Share: Rs. 56,850; Employer Share: Rs. 37,343; Pension Share: Rs. 41,666)—had been successfully furnished to the petitioner, and it found that the directions issued in the original writ petition had been satisfied.

The authorities provided instructions for the creation of a Universal Account Number (UAN) and Aadhaar linking to facilitate the final settlement.

The contempt petition was closed, and no costs were awarded; the petitioner was advised to complete the mandatory Joint Declaration for account settlement.