Contempt jurisdiction over tribunal orders extends where the tribunal is judicially subordinate and wilful disobedience is proved.

The Company Law Board was treated as a court subordinate to the High Court for contempt purposes because it exercised judicial powers under the Companies Act, its orders were appealable to the High Court, and its proceedings had court-like attributes. The contempt petition was held to be within limitation because initiation occurred within the one-year period prescribed for contempt proceedings, and later procedural steps did not defeat timeliness. On the facts, continued demolition despite a status quo order, supported by the Commissioner's report and the tribunal's findings, established wilful disobedience and civil contempt against the fifth respondent alone, with penal consequences and costs.

---

---

Issues: (i) whether the Company Law Board is a court subordinate to the High Court for the purposes of section 10 of the Contempt of Courts Act, 1971; (ii) whether the contempt petition was barred by limitation; and (iii) whether the fifth respondent wilfully disobeyed the status quo order and committed contempt.

Issue (i): whether the Company Law Board is a court subordinate to the High Court for the purposes of section 10 of the Contempt of Courts Act, 1971.

Analysis: The Company Law Board exercised judicial powers under section 10E of the Companies Act, 1956, its orders were appealable to the High Court, and its proceedings had the attributes of a court. The statutory scheme and the appellate structure made it judicially subordinate to the High Court. The availability of powers under its own regulations did not exclude the High Court's contempt jurisdiction.

Conclusion: Yes. The Company Law Board is a court subordinate to the High Court for the purposes of section 10 of the Contempt of Courts Act, 1971.

Issue (ii): whether the contempt petition was barred by limitation.

Analysis: Section 20 requires initiation within one year of the alleged contempt. The contempt application before the Company Law Board was filed within one year of the status quo order, and the present contempt petition before the High Court was filed within that statutory period. The later steps in the contempt process did not defeat limitation once initiation had occurred in time.

Conclusion: No. The contempt petition was within limitation.

Issue (iii): whether the fifth respondent wilfully disobeyed the status quo order and committed contempt.

Analysis: The Advocate Commissioner's report and the Company Law Board's findings established that demolition continued despite the restraint order. The fifth respondent was found present at the site when demolition was in progress, and he offered no effective rebuttal or apology. The evidence satisfied the requirement of wilful and deliberate disobedience beyond reasonable doubt, amounting to civil contempt.

Conclusion: Yes. The fifth respondent was guilty of civil contempt.

Final Conclusion: The contempt jurisdiction of the High Court was held maintainable, the proceeding was held timely, and contempt was established against the fifth respondent alone, resulting in penal consequences and costs.

Ratio Decidendi: A statutory tribunal that decides disputes judicially and whose orders are appealable to the High Court is subordinate to the High Court for contempt purposes, and wilful breach of its order may be punished by the High Court when the contempt is initiated within the limitation period.

---