Dismissed¶28

Vinod Kumar Garg & Ors. v. New Delhi Municipal Council & Ors.

Delhi HC17 Feb 2026W.P.(C)/17882/2025

Case brief

AI extract

What is this about?

Contempt jurisdiction limits; wilful and deliberate disobedience; Central Administrative Tribunal Principal Bench; New Delhi Municipal Council (NDMC); Tribunal order dated 12.01.2024; OA No.18/2020; reasoned and speaking order; compliance order dated 18.07.2025; fresh Original Application remedy; Articles 226/227; writ of Certiorari; W.P.(C) 17882/2025; Vinod Kumar Garg; Delhi High Court; decision dated 17.02.2026.

What did the court decide?

Contempt jurisdiction is limited and circumscribed: while examining a plea of contempt, the Court/Tribunal is only concerned with whether there has been wilful and deliberate disobedience of the direction issued by it. ¶21

Vinod Kumar Garg & Ors. Vs New Delhi Municipal… — Writ and Judicial Review | Delhi HC (2026)

What the court decided

AI extract

Outcome

Dismissed

¶28

Issue for consideration

Whether the directions issued by the Tribunal on 12.01.2024 were duly complied with, and whether the order dated 18.07.2025 is reasoned and speaking. +1 more

¶19

Court's answer

The direction contained in the order dated 12.01.2024 required the Respondents to reconsider the Petitioners' claim; following it, the Respondents passed an order dated 18.07.2025 dealing with the claim during the pendency of the contempt proceedings, and the Tribunal accordingly closed the contempt proceedings.

¶25

Ratio / Principle

¶21

Key takeaways

The correctness, adequacy, or legal sustainability of an order passed in purported compliance of a direction does not ordinarily fall within the scope of contempt jurisdiction.ratio¶21
If the Petitioners are aggrieved by the contents or reasoning of the order dated 18.07.2025, the appropriate remedy is to challenge it by filing a fresh OA before the Tribunal, not by pursuing contempt proceedings.ratio¶27
Questions of contempt proceedings are not intended to serve as a substitute for appellate or original adjudicatory remedies; whether the compliance order is sufficiently reasoned or correctly appreciates the Tribunal's directions requires substantive adjudication.

Detailed headnote1 paragraphs

Delhi High Court (Justices Anil Kshetarpal and Amit Mahajan, sitting together) dismissed W.P.(C) 17882/2025, filed under Articles 226/227 of the Constitution of India seeking certiorari to quash the order dated 23.07.2025 of the Central Administrative Tribunal, Principal Bench, New Delhi, whereby contempt proceedings initiated for alleged non-compliance of the Tribunal's order dated 12.01.2024 (disposing of OA 18/2020 with a direction to take a relook and pass a reasoned and speaking order within three months) were closed. Held: contempt jurisdiction is limited to determining wilful and deliberate disobedience of a direction; the correctness, adequacy or legal sustainability of the purported compliance order dated 18.07.2025 (rejecting the Petitioners' representation) pertains to merits requiring substantive adjudication, and the proper remedy for grievance against that order is a fresh Original Application before the Tribunal, not contempt proceedings. Petition and pending applications dismissed.

¶1

$~80

¶2

* IN THE HIGH COURT OF DELHI AT NEW DELHI

¶3

- W.P.(C) 17882/2025, CM APPL. 73908/2025 and CM APPL. 73910/2025

¶4

VINOD KUMAR GARG & ORS. .....Petitioners Through: Mr. Rajinder Wali, Adv.

¶5

versus

¶6

NEW DELHI MUNICIPAL COUNCIL & ORS.

¶7

.....Respondents Through: Ms. Rashmi Chopra, Sr. Adv. along with Mrs. Shriparna Chaterjee, Mr. Puneet Rathi and Mr. Sharuk Qureshi, Advs.

¶8

CORAM:

¶9

HON'BLE MR. JUSTICE ANIL KSHETARPAL HON'BLE MR. JUSTICE AMIT MAHAJAN

¶10

O R D E R % 17.02.2026

¶11

The present petition has been filed under Articles 226/227 of the Constitution of India, 1950, seeking issuance of a Writ in the nature of Certiorari to quash the order dated 23.07.2025 passed by the Central Administrative Tribunal, Principal Bench, New Delhi [hereinafter referred to as „Tribunal‟], whereby the contempt proceedings initiated by the Petitioners (Applicants before the Tribunal), for alleged non-compliance of Order dated 12.01.2024, came to be dismissed.

¶12

The brief facts leading to the filing of the present petition are set out hereinafter.

¶13

The Tribunal, vide its Order dated 12.01.2024, while disposing of Original Application (OA) No.18/2020 filed by the Petitioners, issued the following direction:

¶14

This is a digitally signed order.

¶15

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 21/02/2026 at 12:29:40

¶16

“24. In this conspectus, we deem it appropriate to dispose of the O.A. with a direction to the respondents to have a relook in the matter and decide the claim of the applicants, in terms of the directions of the Hon’ble High Court of Delhi, referred to above, by passing a reasoned and speaking order within a period of three months from the date of receipt of a copy of this order.”

¶17

Alleging non-compliance of the aforesaid directions, the Petitioners filed a petition initiating contempt proceedings before the Tribunal on the ground that the order dated 12.01.2024 has not been complied with. In response thereto, the Respondent filed a compliance affidavit enclosing an order dated 18.07.2025, whereby the representation of the Petitioners was rejected.

¶18

Notably, the order dated 18.07.2025 was passed during the pendency of the contempt petition. Thereafter, the Tribunal, upon noticing that the said order has been passed, proceeded to close the contempt proceedings.

¶19

Learned counsel representing the Petitioner submits that the directions issued by the Tribunal on 12.01.2024 have not been duly complied with and the Order dated 18.07.2025 is neither reasoned nor a speaking.

¶20

This Court has considered the submissions made by the learned counsel.

¶21

It is well settled that the jurisdiction exercised by a contempt court is limited and circumscribed. While examining a plea of contempt, the Court/Tribunal is only concerned with the question whether there has been wilful and deliberate disobedience of the direction issued by it. The correctness, adequacy, or legal sustainability of an order passed in purported compliance does not ordinarily fall within the scope of contempt jurisdiction.

¶22

In the present case, the direction contained in the order dated

¶23

This is a digitally signed order.

¶24

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 21/02/2026 at 12:29:40

¶25

12.01.2024 required the Respondents to reconsider the claim of the Petitioners. Following which, the Respondents, during the pendency of the contempt proceedings, passed an order dated 18.07.2025 dealing with the claim of the Petitioners.

¶26

Whether the said order sufficiently meets the requirement of being reasoned or speaking, or whether it correctly appreciates the directions of the Tribunal, are matters that pertain to the merits of the decision and would necessarily require substantive adjudication. Such issues cannot be gone into in proceedings for contempt, which are not intended to serve as a substitute for appellate or original adjudicatory remedies.

¶27

If the Petitioners are aggrieved by the contents or reasoning of the said order, the appropriate remedy available to them is to challenge the same by filing a fresh OA before the Tribunal and not by pursuing contempt proceedings.

¶28

With these observations, present Petition, along with pending applications, stand dismissed.

¶29

ANIL KSHETARPAL, J.

¶30

AMIT MAHAJAN, J.

¶31

FEBRUARY 17, 2026 s.godara/hr

¶32

This is a digitally signed order.

¶33

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 21/02/2026 at 12:29:40

Vinod Kumar Garg & Ors. v. New Delhi Municipal Council & Ors.

Case brief

What is this about?

What did the court decide?

Vinod Kumar Garg & Ors. v. New Delhi Municipal Council & Ors.

Case brief

What is this about?

What did the court decide?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

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