Contempt for breach of injunction cannot be sustained against non-parties absent aid or abetment of a bound party's disobedience.

An injunction operates in personam, so contempt for disobedience ordinarily lies only against persons named in the decree. Non-parties may be liable only if they aid and abet a breach by an enjoined person. On the facts, the opposite parties were not defendants and were not named in the injunction, and there was no principal contemnor whose breach they could have assisted. The court therefore held that committal for contempt could not be sustained against them, while leaving any execution remedy under Order 21 Rule 82 CPC open.

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Issues: Whether persons who were not parties to the injunction could be committed for contempt on the footing that they aided and abetted its breach.

Analysis: An injunction operates in personam, and the ordinary rule is that contempt for disobedience lies against persons named in the decree. Liability of non-parties may arise only where they aid and abet a principal offender in the breach. On the facts, none of the opposite parties were defendants to the suit or named in the injunction, and there was no principal contemnor whose breach could be aided or abetted. The authority relied on for third-party contempt did not apply where the enjoined party itself had not disobeyed the order. The possibility of an execution remedy under Order 21, Rule 82 of the Code of Civil Procedure, 1908 was left open, but no opinion was expressed on it.

Conclusion: The rule for committal for contempt could not be sustained against the opposite parties.

Final Conclusion: The application failed because contempt could not be founded against non-parties to the injunction in the absence of a principal breach by an enjoined person.

Ratio Decidendi: A person not bound by an injunction cannot be punished for contempt merely for doing an act forbidden by it unless that person has aided and abetted a breach by the party actually bound by the injunction.

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