Contempt requires wilful disobedience; substantial compliance bars re-litigation of disputed GST quantum in contempt proceedings.

Contempt jurisdiction requires proof of wilful disobedience of a clear and specific court direction. Where the writ court had remitted the matter for calculation and payment of a withheld GST-related amount, and the authority subsequently determined and paid a quantified sum, substantial compliance was found. The contempt court could not re-open the dispute or act as an appellate forum on the quantum calculated by the authority. As no wilful or deliberate non-compliance of the writ order was established, contempt was not attracted, and any remaining grievance on entitlement or quantum had to be pursued before the appropriate forum.

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Issues: Whether the contempt cases disclosed wilful and deliberate non-compliance of the writ court's order warranting exercise of contempt jurisdiction.

Analysis: The writ court had remitted the matter to the authority to calculate and pay the withheld GST-related amount, and the authority had thereafter determined and paid a quantified sum. In contempt proceedings, the decisive inquiry is whether there is wilful disobedience of a clear command. Where the original order has substantially been carried out and the surviving grievance relates to the quantum calculated by the authority, the contempt court does not sit in appeal over that determination or substitute its own view on entitlement.

Conclusion: No wilful or deliberate non-compliance was established, and contempt jurisdiction was not attracted.

Ratio Decidendi: Contempt lies only on proof of wilful disobedience of a specific direction, and it cannot be used to re-open a dispute on quantum where the underlying order has been substantially complied with and the remaining issue is left to be pursued before the appropriate forum.

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