Wilful disobedience not established where compliance was partly made and missing records were explained; contempt proceedings failed.

Delhi HC held that contempt for non-compliance was not made out because the record did not establish wilful disobedience of its earlier directions. The court noted that cloning and handing over data from the digital devices had already been complied with, and the remaining documents were not supplied because the relevant file was untraceable, with tracing steps already underway. In the absence of deliberate or intentional defiance, the respondents' conduct did not attract contempt jurisdiction, and the contempt petitions were dismissed.

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Issues: Whether the respondents were guilty of wilful disobedience of the directions issued earlier by the Court and liable to be proceeded against in contempt.

Analysis: The petitions concerned alleged non-compliance with the earlier order directing supply of duly endorsed copies of documents seized under a panchnama. The material on record showed that the directions regarding cloning and handing over of data from the digital devices had already been complied with. As regards the remaining documents, the respondents explained that the relevant file was untraceable, that tracing steps had been initiated, and that the circumstances did not indicate deliberate or intentional non-compliance.

Conclusion: The Court found no wilful disobedience of its earlier directions and declined to hold the respondents in contempt.

Final Conclusion: The contempt petitions were dismissed on the ground that the respondents' conduct did not amount to wilful disobedience of the earlier order.

Ratio Decidendi: Contempt for non-compliance is not made out where the alleged default is explained by circumstances showing absence of wilful disobedience and the record does not establish deliberate defiance of the court's directions.

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