Civil contempt requires a clear judicial command and wilful disobedience; ambiguous orders cannot be stretched to decide disputed rights.

Civil contempt requires proof of a clear, specific judicial direction and wilful, deliberate disobedience beyond reasonable doubt. Where earlier orders are general, context-specific, or open to more than one reasonable interpretation, contempt jurisdiction cannot be used to enlarge those orders or to resolve disputed business rights and factual controversies. The proper course in such circumstances is to seek clarification or pursue substantive remedies in the pending proceedings. On the facts, the relied-upon orders did not impose an unequivocal restraint on the alleged conduct, so intentional violation was not established and contempt was not made out.

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Issues: Whether the alleged breach of the Tribunal's earlier orders amounted to civil contempt by wilful disobedience, and whether the contempt petition was maintainable on the facts.

Analysis: Civil contempt requires proof of a clear disobedience of a judicial direction and that the disobedience was wilful, deliberate, conscious and intentional. Where the earlier orders are general in nature, relate to a different context, or are capable of more than one reasonable interpretation, contempt jurisdiction cannot be used to expand those orders or to resolve disputed questions of fact and underlying business rights. The proper course in the presence of ambiguity or broader factual is to seek clarification or pursue substantive remedies in the pending proceedings, rather than invoke contempt as a substitute for adjudication. Applying these principles, the three orders relied upon did not contain a specific and unequivocal restraint prohibiting the conduct alleged in the contempt case, and no intentional violation was established.

Conclusion: The charge of contempt was not made out, as wilful disobedience of a clear and specific order was not proved.

Ratio Decidendi: Contempt jurisdiction can be invoked only for breach of a clear and specific judicial command proved to have been wilfully and intentionally violated beyond reasonable doubt; it cannot be used to decide disputed substantive rights or to read into an order restrictions that are not expressly or unambiguously contained in it.

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