Unsubstantiated allegations of non-compliance cannot sustain contempt proceedings after documented compliance.

The Petitioners filed a contempt petition under Sections 10 and 12 of the Contempt of Courts Act, 1971, read with Section 151 CPC, alleging non-compliance with the Delhi High Court’s orders dated 22 November 2013 and 10 January 2017 in Bam Dev Chhetri & Ors. v. Jawaharlal Nehru University & Anr.

The Respondents relied on a Compliance Report stating that the pay of certain Petitioners had been restored and revised in accordance with the applicable pay scales and CPC recommendations, while the remaining Petitioners had already been drawing a higher scale and therefore required no further revision.

In April 2023, the Court granted the Petitioners liberty to file a reply affidavit or communicate specific outstanding monetary claims to the Registrar, with a corresponding direction to the University to respond.

No such communication, reply affidavit, tabulation of arrears, or supporting material was filed by the Petitioners.

The Respondent thereafter filed a Short Compliance Affidavit dated 5 January 2026, asserting that the Court’s directions had been fully implemented and that no monetary or service-related dues remained payable.

Whether the Respondents had complied with the directions contained in the High Court’s orders dated 22 November 2013 and 10 January 2017, so as to negate the allegation of contempt?

Whether the contempt proceedings should remain pending in the absence of any specific material from the Petitioners demonstrating outstanding dues or non-compliance?

The Court exercised jurisdiction under Sections 10 and 12 of the Contempt of Courts Act, 1971, concerning contempt jurisdiction and punishment for contempt, read with the inherent procedural power under Section 151 CPC.

The governing principle applied was that contempt proceedings require a demonstrated failure to comply with the Court’s directions; where the alleged contemnor produces material showing compliance and the complainant fails to identify any specific continuing breach, arrears, or unperformed obligation, the proceedings need not be continued.

The Court also applied the procedural principle that a party alleging non-compliance must place concrete and verifiable particulars of the alleged default before the Court, particularly when given an express opportunity to do so.

The Respondents produced records showing restoration and revision of pay for the concerned employees, while explaining that two Petitioners had already continuously received the higher applicable pay scale and therefore did not require a fresh revision.

The Court treated the Compliance Report of 22 November 2022 and the Compliance Affidavit of 5 January 2026 as sufficient material supporting compliance.

Although the Petitioners orally asserted that no payments had been made, they had not filed the promised reply affidavit, quantified the alleged arrears, or identified any particular direction that remained unimplemented despite the opportunity granted in April 2023.

In the absence of specific contrary material, the Court found no evidentiary basis to conclude that the Respondents had disobeyed the earlier orders or that any actionable contempt persisted.

It therefore declined to keep the contempt proceedings pending and disposed of the contempt petition along with all pending applications, with no further directions.