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Dr. Naresh Kumar vs. Shri Ajay Kumar Bhalla & Ors.

Contempt Case (Civil) · 2026:DHC:8262Decided 24 Sept 2026New Delhi Bench
CONT.CAS(C) 529/2020CNR: DLHC010247502020
Justice Harish Vaidyanathan Shankar

Background

Dr. Naresh Kumar filed a contempt petition alleging the respondents (including a senior Ministry of Home Affairs official) had wilfully disobeyed a 2020 court order directing a Review Departmental Promotion Committee (DPC) to consider his case for promotion to CMO (OG) under a specific pay scheme. He argued that his continued non-consideration for a later, higher post (DIG) meant the original order remained unimplemented.

Decision Breakdown

The Court found the respondents had in fact complied with the specific direction in the earlier order: the petitioner had been promoted to CMO (OG) as ordered, and had even been further promoted to CMO (SG) since then. Since the scope of contempt proceedings is confined to the exact directions given in the order allegedly violated, and the order never addressed promotion to DIG, the Court held the petitioner could not use contempt proceedings to expand relief to a promotion issue never covered by the original order, and dismissed the petition.

Lesson Learnt

A contempt petition can only enforce the specific directions actually given in an earlier court order: it cannot be used as a backdoor route to seek a different or larger relief (like promotion to a further post) that the original order never granted.

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