Wilful disobedience and civil contempt can follow repeated breach of undertakings, dishonoured cheques, and deliberate non-payment.

Wilful disobedience and civil contempt arose from repeated breach of a Memorandum of Understanding and successive undertakings recorded before the Court. The respondent acknowledged liability, agreed to pay admitted dues in instalments, issued post-dated cheques, and gave further assurances during contempt proceedings, but defaulted repeatedly and the cheques were dishonoured. The Court treated this conduct as deliberate and contumacious, and rejected the plea that personal liability could not attach merely because the respondent was a director, noting that a director may be proceeded against where contempt is committed with consent, connivance, or attributable neglect. The respondent was held guilty of contempt.

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Issues: Whether the respondent committed wilful disobedience and civil contempt by breaching the Memorandum of Understanding and successive undertakings recorded by the Court.

Analysis: The respondent repeatedly acknowledged liability, agreed to pay the admitted dues in instalments, issued post-dated cheques, and also gave further undertakings during the contempt proceedings. The record showed repeated non-payment, dishonour of cheques, and breach of the undertakings despite multiple opportunities granted by the Court. The Court held that the respondent's conduct was deliberate and contumacious, and that his plea of being only a director and not personally liable was untenable in view of the statutory rule that a director can be proceeded against where contempt is committed with consent, connivance, or attributable neglect.

Conclusion: The respondent was held guilty of wilful disobedience of the Court's directions and liable for contempt.

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