Civil contempt requires wilful disobedience; a bona fide interpretation dispute over an order will not attract contempt.

Civil contempt under section 2(b) of the Contempt of Courts Act, 1971 requires wilful and deliberate disobedience, and mere non-compliance is insufficient. Where the alleged breach turns on a bona fide dispute about the scope of an earlier order and the effect of a notification abolishing contract labour, contempt jurisdiction is not attracted. The Supreme Court declined to resolve the underlying entitlement of the six sweepers in contempt proceedings and found no deliberate flouting of the order. The contempt petition was therefore dismissed, leaving any substantive remedy to be pursued separately.

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Issues: Whether the respondents were guilty of civil contempt for not absorbing and regularising the six sweepers, and whether the non-absorption amounted to wilful disobedience of the Court's earlier order.

Analysis: Civil contempt under section 2(b) of the Contempt of Courts Act, 1971 requires wilful disobedience, and mere non-compliance is not enough. The dispute turned on the scope of the earlier order, the notification abolishing contract labour, and whether the six sweepers working in the car park area fell within the covered category. The Court declined to decide that underlying entitlement question in contempt proceedings and accepted that the respondents' stand was based on a bona fide interpretation of the order and notification. In the absence of deliberate flouting, the matter did not disclose contempt.

Conclusion: No civil contempt was made out; the petitioners failed to establish wilful disobedience, and the contempt petition was dismissed.

Final Conclusion: The Court held that a genuine interpretative dispute over the reach of the earlier order could not be converted into contempt, leaving the petitioners to pursue any substantive remedy separately.

Ratio Decidendi: For civil contempt, wilful and deliberate disobedience must be proved, and where non-compliance is traceable to a bona fide interpretation dispute over the operative order, contempt jurisdiction is not attracted.

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