Since \(f\) is a constant
\[
\boxed{
\frac{d}{dt} \left( \frac{\zeta + f}{H} \right) = 0
}
\]
Following the motion of each fluid column
\[
\Pi_s = \frac{\zeta + f}{H}
\]
is conserved. If \(H\) increases, the absolute (and hence relative) vorticity must increase to keep \(\Pi_s\) constant for the column.
Note that if \(\zeta\) is originally zero, it will remain so only if \(H\) remains constant; relative vorticity is produced by column stretching in the field of planetary vorticity \(f\).
1 Pedlosky, J. (1982). Geophysical Fluid Dynamics. Springer study edition. Springer, Berlin, Heidelberg.