Civil contempt necessitates clear, irrefutable evidence of willful, deliberate disobedience of a court order. It cannot be employed as a substitute for execution or appellate challenge to correct administrative interpretations, provided the authority has acted in good faith based on available data.

J U D G M E N T

ANIL KSHETARPAL, J. :

1. The present Petition, filed under Articles 226/227 of the Constitution of India, challenges the order dated 15.10.2025 [hereinafter referred to as ‘Impugned Order’] passed by the Central Administrative Tribunal [hereinafter referred to as ‘CAT/Tribunal’] in Contempt Petition No. 982/2024 in O.A. No. 2912/2023. By the Impugned Order, the Tribunal dismissed the Contempt Petition, holding that the Respondents had complied with its earlier directions of 07.08.2024 and that no contempt was made out. The Petitioner seeks quashing of the CAT’s Impugned Order and a direction to allocate him the post of Indian Administrative Service (IAS) in the EWS quota (Economically Weaker Section), contending that the Respondents ignored material communications and thereby violated the Tribunal’s directions.

FACTUAL BACKGROUND:

2. The Petitioner appeared in the Civil Services Examination, 2022, and secured a rank entitling him to appointment as an IAS officer under the EWS category. The Petitioner’s father was an employee in Government service, and his mother filed Income Tax Returns (ITRs) for the relevant assessment year (AY 2021-22) in which a sum of Rs. 49,599 was shown as income under the head “Salaries”. The Petitioner’s family holds a EWS (Income & Asset) certificate, granted by the competent revenue authority (Tehsildar).

3. Notwithstanding his rank and certificate, the Petitioner was allotted the Indian Police Service (IPS) instead of the IAS. Candidates ranked lower than him, and who also claimed EWS status, were appointed as IAS officers. The cause for this apparent anomaly was communicated to the Petitioner: the DoPT treated the Petitioner’s family income as exceeding the EWS income limit of Rs.8 lakh for the relevant year, on account of the Rs.49,599 appearing in his mother’s ITR for AY 2021-22. The Petitioner therefore filed a representation in August 2023 seeking rectification, to no avail.

4. Consequent thereto, the Petitioner filed O.A. No. 2972/2023 before the CAT (Principal Bench), challenging his allocation. The Tribunal disposed of that O.A. by its order dated 30.04.2024. Aggrieved by the operative directions, the Petitioner filed Revision Application No. 50/2024 for review/modification of the order of 30.04.2024. The DoPT also filed a cross-revision (R.A. 60/2024). The CAT heard these revision applications and, on 07.08.2024, passed a reasoned order modifying the earlier order (30.04.2024). The concluding directions of the order dated 07.08.2024 are reproduced below:

“14. … In the instant OA, the respondents have not disputed the certificate issued by the Tehsildar … and the Income Tax Return of the mother of the applicant. There is nothing on record to establish that the respondents have … got the documents verified by the Tehsildar as prescribed under the DoPT OM dated 31.01.2019.

15. In view of the absence of the verification exercise undertaken by the respondents with respect to the certificate issued by the Tehsildar and omitting to confirm the reason for inflation of the income tax return of the mother of the applicant, the OA is disposed of with a direction to the respondents to re-confirm from the CBDT whether income received under various heads by the mother of the applicant as reflected in the ITR was in fact accounted for the relevant financial year 2020-2021 or otherwise; and in case after confirming the same, it is found that the income relates back to earlier years, the benefit of EWS catego