Telangana HC rules no contempt in NIRD case, says “consider” orders don’t mandate regularisation of contract employees

News Citation : 2026 LN (HC) 303

April 22, 2026 : The Telangana High Court has dismissed a contempt petition filed against officials of the National Institute of Rural Development and Panchayati Raj, holding that there was no wilful disobedience of its earlier directions regarding the regularisation of a contractual employee.

The Division Bench of Justice P. Sam Koshy and Justice Namavarapu Rajeshwar Rao delivered the ruling on April 22, 2026, in Contempt Case No. 856 of 2025, clarifying the legal scope of directions such as “consider” in service matters.

The case arose from a long-standing dispute involving the petitioner, V. Srinivas, who had sought regularisation of his services after years of contractual employment. The Central Administrative Tribunal had earlier directed the institute to consider his case for regularisation, and this direction was later upheld by the High Court in 2024 with a clarification that such consideration would apply only if he was otherwise eligible and that appropriate orders should be passed in accordance with law.

Following these directions, the institute issued an order in March 2025 rejecting the request for regularisation but allowing the petitioner to continue on a contractual basis until retirement, along with certain terminal benefits. Challenging this, the petitioner moved the High Court alleging contempt, arguing that the authorities had effectively ignored binding judicial directions and reiterated an earlier rejection.

The High Court, however, found no merit in this contention. It closely examined the language used in its earlier order and held that a direction to “consider” does not mandate a particular outcome. Referring to the Supreme Court’s ruling in A.P.S.R.T.C. v. V. G. Srinivas Reddy, the Bench reiterated that such directions require an authority to apply its mind and take a decision in accordance with law, but do not compel it to grant relief.

The court explained that the phrase “if he is otherwise eligible” imposes a condition requiring the employee to satisfy all applicable criteria, while “pass appropriate orders” grants discretion to the authority to take a lawful and reasoned decision. When these expressions are read together, they make it clear that the authority retains the power to either grant or reject the claim after due consideration.

On facts, the Bench noted that the institute had examined the petitioner’s case, recorded reasons for denying regularisation, and extended certain benefits including continuation in service till retirement and payment of retirement dues. This, the court held, demonstrated compliance with the earlier directions rather than defiance.

Importantly, the court underscored that contempt jurisdiction is limited in scope and cannot be used to test the correctness or legality of an administrative decision. It is concerned only with whether there has been deliberate non-compliance with a court’s order. Since the institute had acted on the direction to consider the case and passed a reasoned order, no case of contempt was made out.

The Bench also clarified that if the petitioner is dissatisfied with the decision rejecting his regularisation, the appropriate remedy would be to challenge that order through legal proceedings, rather than invoking contempt jurisdiction.

With these observations, the High Court closed the contempt case and discharged the respondents, while leaving open the petitioner’s right to pursue other remedies available under law.

Case Reference : Contempt Case No. 856 of 2025, V. Srinivas v. Manoj Kumar (Registrar, National Institute of Rural Development); Counsel for Petitioner: Mr. Avadesh Narayan Sanghi, Senior Counsel; Counsel for Respondents: Mr. Sai Eshwar, appearing on behalf of Mr. N.B. Sudarshan.