Y. Sai Satya Prasad & Ors. vs. D. Prabhakara Rao & Ors.
Background
Following the bifurcation of Andhra Pradesh, a dispute arose over allocating employees of the erstwhile combined State Power Utilities between the successor Andhra Pradesh and Telangana power companies. The Supreme Court had earlier accepted a "One Man Committee" report (by Justice D.M. Dharmadhikari) and, by judgment dated 7 December 2020, directed both states' power utilities to implement and absorb all employees on the Committee's final list. 84 petitioners, employees who had already been relieved by the Andhra Pradesh Power Utilities on the strength of this list, alleged that the Telangana Power Utilities (TS Genco, TS Transco, TSSPDCL and TSNPDCL) then issued office orders in December 2020 that arbitrarily left them out of absorption, in defiance of the Court's ruling, leaving them without a job or salary.
Decision Breakdown
The Supreme Court held that once the One Man Committee's Final Report and List had been accepted and made binding by its own earlier order, any deviation from it by the Telangana Power Utilities amounted to willful disobedience. It rejected the Telangana Power Utilities' attempt to re-raise "reciprocity" and "financial neutrality" objections that had already been considered and dismissed in the Court's December 2020 order, holding there must be finality to litigation. The Court found the Telangana Power Utilities guilty of civil contempt for deliberately disobeying its judgment dated 7 December 2020. However, before deciding the actual punishment, it gave the contemnors one final opportunity: two weeks to absorb all 84 petitioners as per the approved list and to pay them salary and service benefits from the date they were relieved by the Andhra Pradesh Power Utilities, with the question of sentence to be taken up on 31 October 2022 depending on compliance.
Lesson Learnt
A government body or public utility that has lost a legal battle before the Supreme Court cannot evade compliance by repeatedly re-raising the same objections through fresh administrative orders, doing so exposes it (and its officers) to a finding of contempt of court, and the Court can hold a party guilty of contempt while still giving a final, time-bound chance to comply before imposing punishment.