Substantial compliance defeats contempt where inspection was allowed and no wilful disobedience of the court order was shown.

Contempt for wilful disobedience was not made out where the order for supply of documents and inspection in a departmental proceeding was substantially complied with by permitting inspection within time. The alleged failure to furnish copies was treated as secondary to the main relief of inspection and did not show deliberate defiance. The Court reiterated that contempt jurisdiction should not be used for trifling or trivial defaults, and that an ambiguous or imprecise order, or one not proved to have been wilfully disobeyed, cannot sustain a contempt finding.

---

---

Issues: Whether the appellant was guilty of contempt for wilful disobedience of the High Court's order directing supply of documents and inspection in the departmental proceeding.

Analysis: The order was substantially complied with when inspection of the records was permitted within time, and the alleged non-supply of copies did not amount to deliberate disobedience. The demand for copies was treated as secondary to the main relief of inspection, and the Court held that contempt jurisdiction should not be invoked for trifling or trivial defaults. The Court also accepted that an ambiguous or imprecise order, or one not shown to have been wilfully disobeyed, cannot sustain a contempt finding.

Conclusion: The appellant was not guilty of contempt and the conviction was unsustainable.

---