Contempt requires breach of a clear direction; non-release of goods was not contempt without an order to release them.

Non-release of goods did not amount to contempt because the earlier order contained no direction requiring release. The court examined the prior order and held that, without a specific mandate to release the goods, the alleged failure could not amount to disobedience of that order. If the goods were to be released, the proper remedy lay in separate proceedings for that relief, not in contempt. No case was therefore made out for initiation of contempt proceedings.

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Issues: Whether non-release of the goods amounted to breach of the earlier order so as to justify initiation of contempt proceedings.

Analysis: The prior order was examined and found not to contain any direction for release of the goods. In the absence of such a direction, the alleged non-release could not be treated as disobedience of the earlier order. The remedy, if any, lay in appropriate proceedings for release of the goods, not in contempt.

Conclusion: No case was made out to initiate proceedings for contempt.

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