Tribunal cannot block implementation of a final High Court judgment; deliberate delay in compliance may amount to contempt.
A subordinate tribunal cannot suspend proceedings that were expressly issued to implement a final High Court judgment, because such interim interference would obstruct execution of the binding mandate of a superior constitutional court. The tribunal may have jurisdiction over the service dispute, but that jurisdiction does not extend to neutralising a step taken solely to give effect to the High Court's final directions. The text also states that deliberate delay in reversion, despite an attained-finality judgment declaring the employee ineligible for promotion, can amount to willful disobedience. The official respondents' belated compliance was treated as neither bona fide nor justified, and contempt was found, with sentence left for separate consideration.
Issues: (i) Whether the Tribunal could suspend an order passed by the High Court that had attained finality and was stated to be in implementation of that order. (ii) Whether the official respondents were guilty of contempt for delaying and obstructing implementation of the High Court's directions regarding reversion of the third respondent.
Issue (i): Whether the Tribunal could suspend an order passed by the High Court that had attained finality and was stated to be in implementation of that order.
Analysis: The challenged proceedings of the Government expressly recorded that they were issued to implement the High Court's earlier final judgment. The Tribunal's interim suspension of those proceedings necessarily interfered with the execution of the High Court's final mandate. Orders of a superior constitutional court must be followed in letter and spirit, and a subordinate forum cannot sit in judgment over or interdict their implementation on the premise that the matter is sub judice before it. Even though the Tribunal had jurisdiction to entertain the service dispute under the Administrative Tribunals Act, that jurisdiction did not extend to suspending a step taken solely to give effect to the High Court's binding judgment.
Conclusion: The suspension ordered by the Tribunal was unsustainable and the High Court's suspension of that order was maintained.
Issue (ii): Whether the official respondents were guilty of contempt for delaying and obstructing implementation of the High Court's directions regarding reversion of the third respondent.
Analysis: The High Court had already declared the third respondent ineligible for promotion under the unamended service rules, and that judgment had attained finality. Despite this, the respondents continued him in promotional posts and implemented the reversion only after prolonged delay and after contempt proceedings were initiated. The belated compliance was found to be neither bona fide nor justified, and the respondents' conduct was held to amount to deliberate disregard of binding judicial directions.
Conclusion: Respondents 1 to 3 were held guilty of contempt of court for willful disobedience of the High Court's orders.
Final Conclusion: The High Court upheld its supervisory authority over the Tribunal, maintained suspension of the Tribunal's contrary order, and found the official respondents guilty of contempt, while leaving the matter of sentence to be taken up separately.
Ratio Decidendi: A subordinate tribunal cannot suspend or neutralize a step taken in direct implementation of a final and binding High Court judgment, and deliberate delay in complying with such a judgment constitutes willful disobedience amounting to contempt.
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