Baidya Nath Choudhary vs. Dr. Sree Surendra Kumar Singh, Contempt Petition (Civil) No. 1188 of 2018
- ByPravleen Kaur --
- 15 Jun 2025 --
- 0 Comments
The Supreme Court of India, in Baidya Nath Choudhary vs. Dr. Sree Surendra Kumar Singh [Contempt Petition (Civil) No. 1188 of 2018, decided January 8, 2025; 2025 INSC 45], addressed the issue of enforcement of court directions relating to payment of salary arrears and pension benefits to certain employees absorbed into government service.
Facts and Background
The petitioners, including Baidya Nath Choudhary, filed contempt proceedings alleging non-compliance with earlier Supreme Court directions issued in Krishna Nand Yadav & Ors. vs. State of Bihar & Ors. (Civil Appeal No. 2703 of 2017), which dealt with the absorption of employees into government service and their entitlement to salary and pension benefits.
The petitioners contended that despite the Supreme Court’s directions, the respondents had failed to pay salary arrears and pension benefits for the period during which the petitioners were absorbed but allegedly not paid. The respondents disputed the claim, asserting that the petitioners had not actually worked during the relevant period and thus were not entitled to arrears.
Legal Issues
Whether the petitioners were entitled to salary arrears and pension benefits for the period of absorption.
The scope and effect of Supreme Court directions in the earlier case on the present petitioners.
The necessity of fact-finding to determine actual work done and entitlement to benefits.
Supreme Court’s Findings
The Court noted that the petitioners were not parties to the original appeal (Krishna Nand Yadav), and no specific in-personam directions had been issued to them regarding payment of salary or arrears. The Court observed that the question of whether the petitioners had actually worked during the absorption period and their entitlement to salary and arrears was disputed and required a fact-finding inquiry.
The Supreme Court declined to decide the issue in contempt proceedings, emphasizing that such factual disputes necessitate proper adjudication through a trial or inquiry. The Court further observed that the stoppage of pension benefits was a separate issue requiring detailed examination.
The Court directed that the matter be referred to an appropriate forum for a detailed fact-finding process to determine the petitioners’ entitlement to salary arrears and pension benefits, ensuring due process and fair hearing.
Conclusion
The judgment clarifies that:
Contempt proceedings are not the appropriate forum for resolving disputed factual issues regarding salary and pension entitlements.
Proper fact-finding and adjudication are necessary to determine actual work done and corresponding benefits.
Supreme Court directions in earlier cases do not automatically bind non-parties without specific orders.
The Court promotes procedural fairness by directing referral to competent authorities for inquiry and adjudication.
This ruling underscores the importance of due process in service-related disputes and limits contempt jurisdiction to enforcement of clear, unambiguous court orders.
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