Civil contempt and wilful disobedience: apology and later compliance led the court to drop punitive action.

Civil contempt requires wilful disobedience of a court order, and wilfulness may be inferred from persistent non-compliance after service, absence of stay or extension, and disregard of repeated reminders. The conduct here was found unsatisfactory and showed complete disregard of a time-bound direction, but the second respondent offered an unconditional apology and implementation steps had meanwhile been taken. In those circumstances, the court refrained from recording a positive finding of contempt or imposing punishment, accepted the apology, discharged the rule, and awarded costs to the petitioners.

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Issues: Whether the respondents' conduct amounted to wilful disobedience constituting civil contempt, and whether contempt action was warranted.

Analysis: For civil contempt, the essential requirement is wilful disobedience of a court order. Wilfulness may be inferred from proved facts, including persistent non-compliance after service of the order, absence of any stay or extension, and disregard of repeated reminders and warnings. On the material before it, the delay in implementation was plainly unsatisfactory and reflected complete disregard of the time-bound direction. However, the second respondent tendered an unconditional and unqualified apology, and steps had meanwhile been taken to implement the order. In those circumstances, the Court refrained from recording a positive finding of contempt or taking punitive action.

Conclusion: No contempt action was taken. The apology was accepted and the rule was discharged, with costs awarded to the petitioners.

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