Contempt requires wilful disobedience, not compliance with a writ order through application of the amended Modvat law.

Contempt was not established because the authority complied with the earlier writ direction by re-examining the claim and deciding it under the amended Modvat scheme. The prior order required verification of records and disposal in accordance with law, not grant of credit notwithstanding later statutory amendment. The authority allowed the claim for the period covered by the unamended rule but rejected the balance after Rule 57-H was amended and the relevant credit entitlement was deleted. In the absence of a clear and specific mandate to grant relief despite the amendment, there was no wilful disobedience.

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Issues: Whether contempt proceedings were warranted for alleged non-compliance of the earlier writ order by rejecting the petitioner's claim under the amended Modvat scheme.

Analysis: The relief earlier granted required the competent authority to verify the record and pass an order in accordance with law. The subsequent adjudication allowed the claim for the period covered by the unamended rule and rejected the balance claim on the basis that Rule 57-H of the Central Excise Rules, 1944 stood amended with effect from 5-5-1989 by Notification No. 20/89-CE(NT), whereby the relevant credit entitlement for the later period was deleted. Since the authority acted on the amended statutory position and there was no express direction that credit must be granted even after the amendment, the Court found no wilful disobedience of its earlier order.

Conclusion: Contempt was not made out and the petition failed against the respondent.

Ratio Decidendi: No contempt lies where the alleged contemnor complies with the court's direction by deciding the matter according to the applicable amended law, absent a clear and specific mandate to grant the relief despite the statutory change.

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