Civil contempt requires wilful disobedience; non-implementation linked to intervening constraints did not establish deliberate breach.

Civil contempt requires proof of wilful disobedience, meaning a deliberate and intentional breach of a court direction that was capable of compliance in ordinary circumstances, and the failure must be directly attributable to the persons proceeded against. On the materials, non-implementation of the rehabilitation scheme was linked to intervening factors, including disputes over the tripartite agreement, operational difficulties, power supply issues, and financial and logistical constraints. The record did not show any respondent had intentionally or deliberately breached the Court's directions. Civil contempt was therefore not established.

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Issues: Whether the respondents were guilty of civil contempt for wilful disobedience of the Court's orders passed in connection with implementation of the rehabilitation scheme for the mill.

Analysis: Civil contempt requires wilful disobedience, that is, a deliberate and intentional breach of a judgment, direction, order, writ or undertaking. The order alleged to have been disobeyed must be one capable of being complied with in normal circumstances and the alleged failure must be directly attributable to the persons proceeded against. On the materials placed, the non-implementation of the rehabilitation scheme was attributable to several intervening factors, including disputes regarding the tripartite agreement, operational difficulties, power supply issues, and financial and logistical constraints. The record did not establish that any respondent had intentionally and deliberately breached the Court's directions.

Conclusion: Wilful disobedience was not proved and no civil contempt was made out.

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