Civil contempt for wilful disobedience arises when repeated extensions are ignored and clear payment directions remain unmet.

Wilful disobedience of court orders to deposit the awarded amount can constitute civil contempt where the respondent repeatedly takes advantage of extensions yet still fails to comply. The directions here required deposit of 50% of the award and were later reinforced by an express warning of serious consequences for non-compliance. The contention that the award was merely executable and that contempt would not lie was rejected on the facts because the conduct showed repeated default, delay and avoidance of compliance. The plea of financial difficulty was treated as an afterthought and not bona fide. The respondents were held guilty of civil contempt.

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Issues: Whether the respondents were guilty of civil contempt for wilful disobedience of the orders directing deposit of the awarded amount and compliance within the time granted.

Analysis: The order staying the arbitral award required deposit of 50% of the awarded amount, and the time granted by the Court was extended on more than one occasion. The respondents took the benefit of those extensions but still did not deposit the amount. The subsequent order expressly required compliance and warned of serious consequences for non-compliance. The contention that the award was merely executable and that contempt would not lie was rejected on the facts, because the conduct showed repeated default, delay, and avoidance of compliance despite clear directions. The plea of financial difficulty was treated as an afterthought and not bona fide.

Conclusion: The respondents were held guilty of civil contempt for wilful disobedience of the High Court order and the Court's own order.

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