Civil Contempt Explained: Supreme Court Holds No Wilful Disobedience Where Direction on Regularisation Is Implemented Under Existing Policy
Case Name: The Workmen through the Convener, FCI Labour Federation v. Ravuthar Dawood Naseem & Ors.
Citation: 2020 INSC 401
Date of Judgment/Order: 19 May 2020
Bench: A.M. Khanwilkar, Dinesh Maheshwari
Held: The Supreme Court held that civil contempt is not established unless there is clear proof of wilful and deliberate disobedience of a court order, and that compliance with a general direction to regularize workmen under an existing organizational policy cannot be treated as contempt in the absence of a specific mandate to adopt a particular mode of regularization.
Summary: The contempt petitions arose from alleged non-compliance with judgments directing the Food Corporation of India (FCI) to regularize and departmentalize certain contract labourers following abolition of the contract labour system. The underlying industrial awards, affirmed up to the Supreme Court, directed regularization but did not specify the particular labour system under which such regularization was to occur.
The petitioners contended that the workmen ought to have been absorbed under the Departmental Labour System, whereas FCI had regularized them under the Direct Payment System (DPS), which had existed since 1973 and formed part of FCI’s organizational policy. It was argued that adoption of DPS amounted to deliberate defiance of the Court’s directions.
The Supreme Court examined the scope of contempt jurisdiction and reiterated that contempt proceedings are quasi-criminal in nature, requiring proof beyond reasonable doubt of wilful disobedience. The Court found that neither the industrial awards nor the judgments of the High Courts or the Supreme Court contained a specific direction mandating regularization exclusively under the Departmental Labour System. In the absence of such clarity, FCI’s action of regularizing the workers under DPS in accordance with its long-standing policy could not be characterized as contumacious.
The Court further held that contempt proceedings cannot be used to re-interpret, expand, or rewrite the original judgment, nor can new claims be raised that were never adjudicated in the original proceedings.
Decision: All contempt petitions were dismissed. The Supreme Court discharged the notices of contempt, holding that no case of willful or deliberate disobedience was made out, and affirmed that bona fide implementation of court directions under an existing policy framework does not attract contempt jurisdiction.