Status quo orders preserve title, possession and construction, and courts may use inherent powers to stop continuing breach.

A status quo order was treated as preserving the existing position on title, possession and construction, and it did not permit further development activity, transfer of title or parting with possession. Correspondence with authorities for permissions or approvals was not, by itself, prohibited, but any act altering the land's existing condition could be restrained. The Court also noted that, in proceedings to enforce an interim restraint, it may use its inherent powers to prevent continuation of the breach and issue restorative directions to undo changes if necessary, so that the status quo existing on the date of the order is maintained.

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Issues: Whether, in proceedings concerning alleged breach of a status quo order, the Court could issue further directions to prevent continuation of the violation and clarify the effect of the status quo direction.

Analysis: The status quo direction was treated as requiring preservation of the factual position as to title, possession and existing construction, without permitting further development activity, transfer of title or parting with possession. The Court held that correspondence with governmental authorities for permissions or approvals was not, by itself, prohibited, but the parties could not undertake development on the land in a manner altering the existing position. Relying on the Court's inherent powers, it was held that the Court was not powerless to ensure that a continuing violation of an interim restraint did not persist and that restorative directions could be issued to undo alteration of the land if necessary.

Conclusion: The Court held that the respondents were restrained from undertaking development activities, parting with possession, or transferring title during the pendency of the petition, and the application was disposed of with protective directions to maintain the status quo.

Ratio Decidendi: In proceedings to enforce a status quo order, the Court may exercise inherent powers to prevent continuation of the breach and to secure restoration of the position existing on the date of the restraint order.

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