Contempt proceedings require prima facie satisfaction, precise charges and identified contemnors before civil imprisonment can be imposed.

Contempt proceedings carrying civil imprisonment require strict compliance with the two-stage procedure: the adjudicating authority must first record a prima facie view of wilful disobedience, then issue a meaningful show-cause notice with precise charges so the alleged contemnors know the case they must meet. A routine notice without framed charges is insufficient. Where alleged default concerns corporate entities, punishment cannot be imposed in a composite manner without identifying the specific individual contemnors said to have committed the contempt. On these stated procedural deficiencies, the contempt order was treated as unsustainable.

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Issues: Whether the contempt order and consequential civil imprisonment could be sustained when the Adjudicating Authority had not first recorded prima facie satisfaction of contempt, had not issued a proper show-cause notice with precise charges, and had not identified the specific individual contemnors.

Analysis: Contempt proceedings, especially where penal consequences such as imprisonment are imposed, require strict compliance with the settled two-stage procedure. The court must first form a prima facie view that wilful and deliberate disobedience is made out, then communicate the specific allegations through a meaningful show-cause notice so that the alleged contemnors know the case they must meet. A routine notice, without framed charges, is insufficient. Where the alleged default is attributable to corporate entities and the sanction letters were issued separately by different banks on varying terms, punishment cannot be imposed in a composite manner without identifying the individual officers alleged to have committed contempt. The absence of such foundational procedural safeguards renders the contempt determination unsustainable.

Conclusion: The contempt order was held unsustainable for want of the mandatory procedural safeguards, and the appeal succeeded.

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