Civil contempt requires wilful disobedience, and mere non-compliance was not enough on the facts considered.

Civil contempt under the Contempt of Courts Act, 1971 requires proof of wilful disobedience or deliberate breach of a tribunal direction; mere non-compliance is not enough unless the conduct is intentional and unjustified. On the facts, the petitioner did not establish that the change in board position was made with the requisite wilful intent to defy the Tribunal's interim orders. The respondents were therefore not found guilty of contempt.

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Issues: Whether the respondents were guilty of civil contempt for wilful disobedience of the Tribunal's interim orders.

Analysis: Civil contempt under Section 2(b) of the Contempt of Courts Act, 1971 requires proof of wilful disobedience or wilful breach of a court's direction. Mere non-compliance is insufficient unless the disobedience is shown to be deliberate, intentional, and without compelling justification. On the facts, the petitioner failed to establish that the disputed change in the board position was effected with the requisite wilful intent to defy the Tribunal's orders.

Conclusion: The respondents were not guilty of contempt.

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