Wilful disobedience standard defeats civil contempt where financial difficulty explains non-compliance with salary directions.

Civil contempt under section 2(b) of the Contempt of Courts Act, 1971 requires wilful disobedience of a court order. The Bombay HC accepted the respondents' explanation that non-payment of salary and allowances resulted from severe financial difficulties of the trust and school, supported by account statements and balance sheets, rather than deliberate defiance. As the element of wilful disobedience was not proved, contempt was not established against the respondents.

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Issues: Whether the respondents committed civil contempt by wilfully disobeying the earlier court directions to pay salary and allowances to the petitioners.

Analysis: Civil contempt under section 2(b) of the Contempt of Courts Act, 1971 requires wilful disobedience of a court order. The Court accepted the respondents' explanation that non-compliance was attributable to severe financial difficulties of the trust and the school, supported by account statements and balance sheets, and not to deliberate defiance. In these circumstances, the ingredients of wilful disobedience were not made out.

Conclusion: The contempt petition was not maintainable on the facts proved, and no contempt was established against the respondents.

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