Contempt jurisdiction of NCLT extends to IBC proceedings, making its insolvency orders enforceable and restoring the contempt application.

The National Company Law Tribunal's contempt power under Section 425 of the Companies Act, 2013 was read purposively to extend to proceedings where the Tribunal acts as adjudicating authority under the Insolvency and Bankruptcy Code, 2016. The reasoning linked Section 425 with Section 424, the Tribunal Rules and Article 323B, and rejected a narrow view that would confine contempt jurisdiction to matters under the Companies Act alone. On that basis, the dismissal of the contempt application for want of jurisdiction was held unsustainable, the order was set aside, and the contempt application was restored for consideration on merits.

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Issues: (i) Whether the National Company Law Tribunal had contempt jurisdiction, under Section 425 of the Companies Act, 2013, in relation to proceedings under the Insolvency and Bankruptcy Code, 2016. (ii) Whether the order dismissing the contempt application on the ground that the Insolvency and Bankruptcy Code, 2016 is devoid of contempt jurisdiction could be sustained.

Issue (i): Whether the National Company Law Tribunal had contempt jurisdiction, under Section 425 of the Companies Act, 2013, in relation to proceedings under the Insolvency and Bankruptcy Code, 2016.

Analysis: The statutory scheme was read purposively. Section 5(1) of the Insolvency and Bankruptcy Code, 2016 makes the National Company Law Tribunal the adjudicating authority for corporate insolvency matters, while Section 408 of the Companies Act, 2013 constitutes the Tribunal and Section 425 confers on it the same contempt jurisdiction as the High Court in respect of contempt of itself. The decision also relied on the procedural powers under Section 424 and the Tribunal Rules, together with the constitutional framework under Article 323B, to hold that the Tribunal's contempt power is not confined only to matters arising under the Companies Act, 2013.

Conclusion: Yes. The National Company Law Tribunal has contempt jurisdiction in appropriate matters arising under the Insolvency and Bankruptcy Code, 2016.

Issue (ii): Whether the order dismissing the contempt application on the ground that the Insolvency and Bankruptcy Code, 2016 is devoid of contempt jurisdiction could be sustained.

Analysis: Once the Tribunal was found to possess contempt jurisdiction, the foundation of the dismissal order disappeared. The appellate forum held that a restrictive reading would render the insolvency process ineffective and would deprive the Tribunal's directions of enforceability. The impugned order was therefore held to be legally unsustainable, and the contempt application was directed to be restored for consideration on merits with due opportunity to both sides.

Conclusion: No. The dismissal order was set aside and the contempt application was restored for fresh consideration.

Final Conclusion: The appeal succeeded, the impugned dismissal was overturned, and the contempt proceedings were remitted to the adjudicating authority for decision on merits.

Ratio Decidendi: The contempt power conferred on the National Company Law Tribunal by Section 425 of the Companies Act, 2013 extends to its orders passed as the adjudicating authority under the Insolvency and Bankruptcy Code, 2016, and such power must be given a purposive construction to preserve the enforceability of tribunal orders.

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