Contempt requires clear and wilful breach of an unambiguous order; ambiguous directions cannot support punishment.

Contempt requires clear, wilful breach of an unambiguous order; where the earlier direction was read as confined to rent for the admitted leased area, no contempt could be fastened for the disputed larger portion or for alleged construction activity not proved on the material. The Court also reaffirmed that if an order is reasonably capable of two interpretations, contempt will not lie. On the respondent's complaint of interference with school management, the injunction did not establish any violation on the available record, so notice or punishment was not warranted. All contempt petitions were rejected, leaving the parties to pursue their remedies in accordance with law.

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Issues: (i) Whether contempt was made out for alleged non-compliance with the earlier direction regarding rent and construction, and (ii) whether the respondent's contempt petition disclosed any case for notice or punishment.

Issue (i): Whether contempt was made out for alleged non-compliance with the earlier direction regarding rent and construction.

Analysis: The earlier order was read as a whole and was held to have proceeded on the admitted lease of 16,000 square feet, while the larger disputed area remained the subject of a separate specific performance controversy. The direction to clear arrears was confined to rent for the premises admittedly leased out, and the Court held that no rent could be fastened in contempt proceedings for the larger disputed portion. As regards construction, the allegation of violation of the injunction was not established on the material placed, and contempt requires clear proof of wilful disobedience rather than a doubtful or technical breach. The Court also reaffirmed that if an order is reasonably capable of two interpretations, contempt will not lie.

Conclusion: No contempt was made out against the respondent on the alleged non-payment of rent or alleged construction activity.

Issue (ii): Whether the respondent's contempt petition disclosed any case for notice or punishment.

Analysis: The respondent's complaint was that the petitioner had interfered with the school management, but the injunction order related to the existence of the structure and the effect of that structure was not the subject of the appeal. So long as the structures were permitted to remain, violation of the Court's order was not established. On the material available, the petition did not justify issuance of notice.

Conclusion: The respondent's contempt petition also failed.

Final Conclusion: All contempt petitions were rejected, with the parties left to work out their remedies in accordance with law.

Ratio Decidendi: Contempt lies only for clear and wilful breach of an unambiguous order, and where the order is reasonably open to more than one interpretation or the alleged violation is not established on strict scrutiny, punishment cannot follow.

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