Civil contempt requires willful disobedience; documented efforts to comply defeated the allegation.

A land dispute between the complainant’s family and Jawahar Gopal and Sheela Gopal led to a civil suit in which the trial court granted a temporary injunction and directed police implementation.

The order was later affirmed in an appeal before the High Court.

In connected writ petitions, the High Court directed the police to ensure obedience to the civil court’s order and, if they encountered difficulty, to follow the procedure in the DGP’s Circular dated 14 November 2018, including seeking the Director of Prosecution’s opinion and placing it before the civil court.

The complainant alleged that the Whitefield Police Inspector had wilfully disobeyed that direction by allowing interference with his possession.

The Inspector filed an affidavit describing steps taken to implement the civil court’s order and to obtain legal opinions.

Whether the Police Inspector wilfully disobeyed the High Court’s order dated 25 September 2025, so as to constitute civil contempt under Section 2(b) of the Contempt of Courts Act, 1971.

Whether the complainant established entitlement to the further reliefs sought, including police protection and action against alleged trespassers.

Section 2(b) of the Contempt of Courts Act, 1971 defines civil contempt as wilful disobedience of a court’s judgment, decree, direction, order, writ or other process, or wilful breach of an undertaking to a court.

The writ court’s direction required the police to ensure obedience to the civil court’s order and, if they faced difficulty enforcing it, to follow the procedure in the DGP’s Circular dated 14 November 2018, including seeking the Director of Prosecution’s opinion and placing it before the civil court.

Contempt therefore required proof of wilful disobedience, assessed in light of the alleged contemnor’s conduct and compliance with the court’s direction.

The Court considered the Inspector’s affidavit and supporting documents, which recorded his inspection of the property, service of the civil court’s order on a security supervisor, and subsequent steps to obtain legal opinions through the prescribed channels.

The complainant did not dispute the affidavit’s contents or annexures, although he argued that the reported compliance was merely a pretext.

The Court found that the Inspector had exercised due diligence and followed the procedure contemplated by the 2018 Circular after encountering difficulty in enforcing the civil court’s order; the complainant’s reliance on the trial court’s observations did not establish wilful disobedience of the writ court’s order.

The Court also considered Prayer No. 2 vague.

The contempt petition was consigned; the requested reliefs were not granted.