Wilful disobedience of settlement undertaking amounts to civil contempt, justifying imprisonment and continued restraint on property alienation.

Repeated, unexplained non-compliance with a court-recorded settlement undertaking to pay admitted dues was treated as wilful disobedience and civil contempt. The Court found the respondent's later claim of coercion inconsistent with prior acknowledgments, undertakings and partial payments, and held that the default was deliberate and without bona fides. Given the continued failure to purge contempt despite repeated indulgence and the absence of a credible plan to raise funds, imprisonment and fine were imposed. The earlier restraint on alienating specified immovable property was continued until the admitted amount was paid.

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Issues: (i) Whether the respondent had committed civil contempt by wilfully disobeying the settlement undertaking and repeated assurances to pay the admitted amount. (ii) Whether, in view of the respondent's continued default and conduct, a sentence of imprisonment and fine was warranted, and the restraint on dealing with immovable property was to continue.

Issue (i): Whether the respondent had committed civil contempt by wilfully disobeying the settlement undertaking and repeated assurances to pay the admitted amount.

Analysis: The respondent had repeatedly acknowledged the liability under the settlement and had given multiple undertakings before the Court and the Trial Court to clear the admitted dues within the stipulated time. Despite being granted repeated opportunities and despite partial payments at different stages, no meaningful compliance followed. The later plea that the settlement was signed under coercion was found inconsistent with the earlier acknowledgments, undertakings, and admissions of liability. The Court treated the non-payment as deliberate and without bona fides, amounting to wilful disobedience of court orders and breach of undertaking.

Conclusion: The respondent was held guilty of civil contempt.

Issue (ii): Whether, in view of the respondent's continued default and conduct, a sentence of imprisonment and fine was warranted, and the restraint on dealing with immovable property was to continue.

Analysis: The Court noted the prolonged non-compliance despite repeated indulgence, the absence of any serious or credible plan to raise funds, and the respondent's ownership of immovable assets. The Court concluded that the default was conscious and persisted even after multiple opportunities to purge the contempt. In these circumstances, the Court found imprisonment appropriate and also directed that the earlier undertaking restraining alienation of specified properties should continue until the admitted amount was cleared.

Conclusion: The respondent was sentenced to two months' imprisonment and fine, and the restraint on dealing with the specified property was continued until compliance.

Final Conclusion: The contempt petition succeeded, the respondent was convicted for wilful disobedience, punishment was imposed, and the protective restraint against alienation of property was maintained until the admitted dues were paid.

Ratio Decidendi: Repeated, unexplained non-compliance with a court-recorded undertaking to pay an admitted amount constitutes civil contempt and may justify imprisonment where the conduct is deliberate and bona fide compliance is absent.

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