Status quo orders can support protective directions stopping development, title transfers and dispossession during pending proceedings.

A status quo order in contempt proceedings was construed as prohibiting disturbance of the existing position on possession, title and construction over the land. The Court held that parties could seek governmental permissions or approvals, but those steps did not permit alteration of the subject matter during the pendency of the petition. Exercising inherent powers, the Court said it could issue consequential protective directions to prevent continuation of an alleged violation and preserve the property. It therefore directed that the respondents not undertake development, transfer title, or part with possession of the land pending the petition.

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Issues: Whether, in a contempt proceeding arising from an order directing maintenance of status quo, the Court could issue protective directions to prevent continuation of the alleged violation and restrain development activities, transfer of title, or parting with possession of the subject land.

Analysis: The status quo order was construed as forbidding disturbance of the then-existing position regarding possession, title, and construction on the land. The Court held that there was no prohibition against the parties seeking permissions or approvals from government authorities, but such steps did not authorise them to alter the existing state of affairs during the pendency of the matter. Relying on its inherent powers, the Court held that it was not powerless to ensure that an alleged violation of an interim restraint did not continue and could issue consequential protective directions to preserve the subject matter.

Conclusion: The Court held that the respondents could not undertake development on the land, part with possession, or transfer title during the pendency of the petition, and the application was disposed of with these directions.

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