Civil contempt for breach of court undertaking: unconditional settlement payment promise enforced, while no liability attached to SBI's Chairman.

A court-accepted settlement undertaking to pay within a stipulated time was treated as an unconditional obligation, not a promise contingent on sale of assets. Later attempts to add such a condition, together with evidence that payment could have been arranged but was withheld, were found to be knowingly false and to constitute wilful disobedience interfering with the administration of justice. The Reliance companies were therefore held guilty of civil contempt. By contrast, contempt could not be maintained against the SBI Chairman because the payment obligation rested only on the Reliance companies, while SBI's role was confined to a separate sale-of-assets process. The contempt petition against the SBI Chairman was dismissed.

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Issues: (i) Whether the Reliance Companies wilfully breached the undertakings given to the Court and thereby committed civil contempt; (ii) whether contempt proceedings could be maintained against the Chairman of SBI in relation to the settlement and payment obligation.

Issue (i): Whether the Reliance Companies wilfully breached the undertakings given to the Court and thereby committed civil contempt.

Analysis: The undertakings filed after the Court's order were held to be unconditional obligations to pay the settled sum within the stipulated time, and not conditional upon sale of assets. The Court found that the later affidavits and extension requests attempted to insert a sale-of-assets condition contrary to the earlier order and the parties' own prior understanding. The subsequent correspondence showed that the companies could arrange payment but chose not to do so within the time granted, and the later position taken in the reply affidavit was found to be false to their knowledge. The Court held that such conduct amounted to wilful disobedience and interference with the administration of justice.

Conclusion: The Reliance Companies were held guilty of civil contempt for wilful breach of their undertakings.

Issue (ii): Whether contempt proceedings could be maintained against the Chairman of SBI in relation to the settlement and payment obligation.

Analysis: The Court found that the obligation to pay the settlement amount rested on the Reliance Companies alone, while the role of SBI and the Joint Lenders' Forum concerned a separate and independent sale-of-assets exercise. Since SBI had nothing to do with the payment obligation to Ericsson, the contempt allegations against its Chairman were not sustainable.

Conclusion: The contempt petition against the Chairman of SBI was dismissed.

Final Conclusion: The Court upheld contempt against the Reliance Companies, declined to proceed against SBI's Chairman, and directed payment of the outstanding amount with interest and costs to purge the contempt.

Ratio Decidendi: A knowingly false or conditional undertaking that contradicts a court-accepted settlement, followed by deliberate non-compliance despite opportunity to perform, constitutes wilful civil contempt; a contempt petition cannot succeed against a person with no legal responsibility for the undertaking breached.

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