Quasi-criminal contempt requires proof beyond reasonable doubt, and mere rejection after due consideration does not establish wilful disobedience.

Contempt proceedings are quasi-criminal, so wilful disobedience of a court order must be proved beyond reasonable doubt. Mere probabilities or the fact that the petitioner did not obtain the desired result are insufficient. Here, the earlier direction was complied with because the petitioner's case was considered as qualified on the relevant cut-off date, a personal hearing was granted, and the claim was rejected on fitness criteria for promotion. As no deliberate or wilful non-compliance with the order was established, contempt was not made out and the petition failed.

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Issues: Whether the respondents were guilty of wilful disobedience of the Court's earlier order so as to sustain contempt proceedings.

Analysis: A proceeding for contempt is quasi-criminal in nature and the alleged breach must be proved beyond reasonable doubt. Mere probabilities or a failure to secure the result desired by the petitioner is insufficient. The earlier direction required consideration of the petitioner's case by treating him as qualified on the relevant cut-off date. The record showed that the petitioner's case was in fact considered, a personal hearing was given, and the claim was rejected on the ground that he was not fit for promotion under the applicable criteria. On that basis, no wilful or deliberate non-compliance with the Court's order was established.

Conclusion: No contempt was made out and the petition failed.

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