Upon admitted compliance, contempt proceedings may be closed without deciding willful disobedience.

The applicant initiated contempt proceedings alleging non-compliance with the Tribunal’s order in O.A. No. 050/00151/2026.

The underlying direction required the respondent to decide the applicant’s representation by a speaking and reasoned order.

At the contempt hearing, the applicant’s counsel accepted that the direction had been complied with, and the respondent’s counsel confirmed compliance.

The Tribunal noted that Rule 6 of the Contempt of Courts (CAT) Rules, 1992 ordinarily requires contempt proceedings to be dealt with by a Bench of at least two Members.

Whether the contempt petition should be brought to an end after the parties confirmed compliance with the underlying order.

Whether further proceedings, including placing the matter before a two-Member Bench under Rule 6, were necessary when no further proceeding was required to secure compliance.

The Tribunal stated that contempt jurisdiction is concerned with securing compliance with its orders, as reflected in Section 27 of the Administrative Tribunals Act, 1985, and with examining alleged wilful disobedience.

Rule 6 of the Contempt of Courts (CAT) Rules, 1992 provides that contempt proceedings are ordinarily dealt with by a Bench of not less than two Members, subject to its stated exception for contempt in the view, presence, or hearing of a Member.

Rule 24 of the CAT (Procedure) Rules, 1987 empowers the Tribunal to make orders or give directions necessary or expedient to give effect to its orders, prevent abuse of its process, or secure the ends of justice.

The Tribunal also referred to the Supreme Court’s order dated 14 February 2025 in Tirthankar Basu & Ors. v. Nivedita Shukla Verma & Ors., in which contempt proceedings were closed following compliance where keeping them pending would serve no useful purpose.

Both parties confirmed that the direction to decide the representation by a speaking and reasoned order had been complied with, leaving no surviving grievance concerning implementation of the original order.

The Tribunal confined its order to recording that admitted compliance; it expressly made no finding on the merits of the contempt allegation, wilfulness, or the guilt or exoneration of any alleged contemnor, and issued no coercive direction.

In those circumstances, it considered that retaining the petition solely to place it before a two-Member Bench would unnecessarily prolong proceedings.

Relying on Rule 24 and the cited Supreme Court order, it concluded that ending the matter was appropriate.

It dropped the contempt petition as unnecessary, discharged the notices, and made no order as to costs.

The disposition did not adjudicate whether any wilful disobedience had occurred.