Civil contempt requires clear proof of wilful breach of a specific operative court direction, not unsupported assertions.

Civil contempt requires satisfactory proof of deliberate and wilful disobedience of a specific operative court direction. The earlier order required customs authorities to accept a baggage declaration while preserving their statutory power to take appropriate action regarding baggage; reproduction of the prayer was not an operative direction. The available material did not establish non-compliance or intentional disobedience, and bare averments could not support contempt action. Accordingly, no case of civil contempt or wilful disobedience was made out.

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Issues: Whether the respondents wilfully and deliberately disobeyed the Court's earlier order so as to constitute civil contempt.

Analysis: Contempt jurisdiction under the Contempt of Courts Act, 1971 is limited and requires clear proof of deliberate or wilful disobedience. The earlier order required the customs authorities to accept a baggage declaration made under Section 77 of the Customs Act, 1962, while preserving their statutory power to take appropriate action regarding baggage. The introductory reproduction of the prayer did not constitute an operative direction. The material on record did not establish non-compliance, much less intentional disobedience, and bare averments were insufficient to initiate contempt action.

Conclusion: No case of civil contempt or wilful disobedience was established against the respondents.

Ratio Decidendi: Civil contempt requires satisfactory proof of deliberate and wilful disobedience of a specific court direction; an interpretation of the order unsupported by material evidence is insufficient.

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