Mere delay in complying with a court direction is not enough to sustain contempt proceedings.

Mere delay in acting on a representation seeking interest on a refund does not, by itself, justify invocation of contempt jurisdiction. Where the grievance is limited to non-immediate compliance with an earlier court direction, contempt proceedings are not maintainable unless there is more than delay and the conduct amounts to disobedience warranting contempt. On these facts, the contempt petition was held not maintainable and was dismissed.

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Issues: Whether the contempt petition was maintainable on the allegation that the authority had delayed a decision on the representation seeking interest on the refund amount.

Analysis: The grievance was founded only on delay in acting upon the representation submitted pursuant to the earlier liberty granted by the Court. The Court held that such delay, by itself, did not justify invocation of contempt jurisdiction, and that contempt proceedings could not be maintained merely because compliance with the earlier order had not been immediate.

Conclusion: The contempt petition was not maintainable on these facts and was dismissed.

Ratio Decidendi: Mere delay in complying with a court direction, without more, does not constitute contempt so as to sustain contempt proceedings.

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