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Issues: Whether the respondents had wilfully or deliberately disobeyed the Court's order so as to warrant a finding of contempt.
Analysis: A finding of contempt requires clear wilful, deliberate, or reckless disobedience of a subsisting order. Here, the respondents' failure to deliver possession was explained by the initiation of acquisition proceedings under the Land Acquisition Act and by the subsisting status quo order passed by the High Court in challenge to that acquisition. In those circumstances, the non-delivery of possession could not be treated as deliberate defiance of the Court's earlier direction.
Conclusion: No contempt was made out, and the contempt petition was liable to be dismissed.