The Scope of Contempt Jurisdiction Is Limited to Verifying Substantial Compliance with the Court’s Specific Directions

The petitioners filed contempt petitions alleging non-compliance with a Division Bench judgment dated 18.02.2026 in WPPIL No. 70 of 2025.

This original judgment quashed the appointment of Respondent No. 3 (Mr. Dhyani) as Managing Director because the educational qualifications under Rule 9A of the 2021 Rules were not met and the "proviso" for equivalence was not lawfully invoked.

The petitioners contended that despite the quashing order, Mr. Dhyani continued to act as a de facto Managing Director by sending emails to subordinates and projecting authority, thereby willfully violating the court's mandate.

1. Whether the respondents committed "willful disobedience" of the judgment dated 18.02.2026 under the Contempt of Courts Act

2. Whether subsequent conduct of a removed officer (sending emails) falls within the scope of contempt jurisdiction when the State has formally issued relieving orders

The court applied the principles of the Contempt of Courts Act, 1971, focusing on the distinction between administrative compliance and subsequent unauthorized conduct by third parties.

Selection and Appointment of Managing Directors Directors in the Three Corporations Rules, 2021, which governed the initial eligibility dispute.

The court maintained the principle that contempt jurisdiction is limited to verifying the implementation of the court's specific directions and cannot be extended to adjudicate new horizontal disputes or "sham arrangements" if formal compliance is documented.

The Court examined the compliance affidavit filed by the Principal Secretary (Energy), which contained an Office Memorandum dated 26.02.2026 and a charge-taking certificate.

These documents proved that Mr. Dhyani was formally relieved and an IAS officer, Mr. Meharban Singh Bisht, was given additional charge of the post.

The court reasoned that since the State had legally terminated the impugned appointment and made interim arrangements as directed, the "substantial compliance" of the judgment was achieved.

Regarding the petitioners' evidence (emails and screenshots) suggesting Mr. Dhyani was still acting as Managing Director, the Court held that such private actions do not constitute a violation of the court's order by the State authorities. Such grievances regarding de facto functioning are administrative matters for the government to address and fall outside the narrow scope of contempt proceedings.

Consequently, the contempt petitions were closed, and the notices issued to the respondents were discharged.

The Court clarified that it would not look into subsequent developments or "sham arrangements" under contempt jurisdiction, as the primary direction to set aside the appointment and make interim arrangements was followed.