Temporary injunction breach under Order 39 Rule 2-A cannot be enforced after the injunction has been vacated.

Order 39 Rule 2-A CPC applies only to disobedience of a subsisting temporary injunction; once the injunction is vacated, there is no operative order left to obey or enforce. The provision is designed to secure compliance with interim injunctions and punish breach through attachment or civil detention, but those consequences do not survive the cessation of the injunction. Accordingly, action under Rule 2-A cannot be sustained for alleged breach after the interim injunction has been vacated, and the adverse finding was upheld.

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Issues: Whether action under Order 39 Rule 2-A of the Code of Civil Procedure, 1908 could be taken for breach of an interim injunction after the injunction had been vacated.

Analysis: Order 39 Rules 1 and 2 authorise grant of temporary injunction, and Rule 2-A provides consequences for disobedience or breach of such injunction. The provision is intended to secure obedience to the injunction and to remedy the wrong caused by its breach. Once the injunction is vacated, there remains no subsisting order to be obeyed or enforced. The punitive consequences under Rule 2-A, whether by attachment of property or detention in civil prison, are therefore not attracted after the injunction has ceased to exist.

Conclusion: Action under Order 39 Rule 2-A could not be sustained after the interim injunction had been vacated, and the finding against the appellant was upheld.

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