Haldhar Prasad Gupta vs. Deepak Kumar & Ors., Contempt Petition (Civil) No. 110/2019
- ByPravleen Kaur --
- 15 Jun 2025 --
- 0 Comments
The Supreme Court of India, in Haldhar Prasad Gupta vs. Deepak Kumar & Ors. [Contempt Petition (Civil) No. 110/2019, decided January 8, 2025; 2025 INSC 65], addressed the issue of non-compliance with earlier Supreme Court directions regarding the payment of salary arrears, pension, and other benefits to employees absorbed into government service.
Facts and Background
Haldhar Prasad Gupta filed a miscellaneous application alleging that despite the Supreme Court’s earlier orders in the batch titled Krishna Nand Yadav and Others vs. Magadh University and Others (dated August 31, 2017), the respondents had failed to release salary arrears, pension, and other entitlements. The petitioner was appointed as Lab In-charge in Parvati Science College under B.N. Mandal University and claimed that his absorption was notified after his superannuation, which raised issues regarding payment of arrears and pension benefits.
The respondents contended that payment of arrears could only be made after verifying actual attendance and working days, and pension stoppage was subject to separate adjudication.
Legal Issues
Whether the respondents complied with the Supreme Court’s directions for payment of salary arrears and pension benefits.
The procedural requirements for verifying claims of salary arrears and pension entitlements.
The appropriateness of contempt proceedings in cases involving disputed factual claims.
Supreme Court’s Findings
The Supreme Court observed that the petitioners must submit detailed claims with relevant documents evidencing their actual working period during absorption. The Court emphasized that only after a fair and transparent inquiry verifying attendance and service can payment of arrears and pension be made, adjusting for any amounts already paid.
The Court held that non-compliance with the Supreme Court’s directions without valid reasons could amount to contempt, but disputed factual issues require adjudication through proper inquiry rather than contempt proceedings.
It directed that once claims are received, an inquiry shall be conducted expeditiously, and payments shall be released accordingly. The Court also noted that pension stoppage issues must be examined separately.
Conclusion
The judgment clarifies that:
Compliance with Supreme Court directions regarding salary and pension arrears must be ensured through fair inquiry and verification.
Contempt jurisdiction is not a substitute for fact-finding in disputed claims.
Employees must submit proper documentation to substantiate their claims.
Authorities are obligated to process claims expeditiously and transparently, adjusting payments as necessary.
This ruling balances procedural fairness with enforcement of court orders, ensuring that rightful dues are paid without compromising judicial process.
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