Tribunal enforcement of final orders: wilful non-compliance can trigger directions to implement and contempt show-cause proceedings.

A tribunal may enforce compliance with its own final order where a party's continued inaction shows wilful disobedience. Here, the Commissioner's failure to implement the earlier order restoring the appellant's right to function as a Custom House Agent was treated as complete defiance, justifying immediate directions for implementation. The Tribunal also required the Commissioner to show cause why contempt proceedings should not be initiated. The operative principle is that a tribunal can compel obedience to its order and seek explanation when its direction is not implemented.

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Issues: Whether directions should be issued for implementation of the Tribunal's earlier order and whether a show cause notice for contempt should issue for non-implementation.

Analysis: The Tribunal found that the Commissioner's inaction amounted to complete defiance of its earlier order setting aside the suspension and permitting the appellant to function as a Custom House Agent. In view of the continuing non-compliance, the Tribunal exercised its procedural power to secure implementation and also required the Commissioner to explain why contempt proceedings should not be initiated.

Conclusion: Directions were issued to forthwith implement the Tribunal's order, and the Commissioner was called upon to show cause against initiation of contempt proceedings.

Ratio Decidendi: A tribunal may compel obedience to its own final order and call for explanation where its direction is wilfully not implemented.

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