01Facts
The Plaintiff (SCIPL/T-Series) filed a suit for recovery of approximately ₹60.23 crores under a Loan Agreement dated 19.05.2021.
p. 2Under the agreement and subsequent amendments, the Plaintiff held a lien on revenues from specific films produced by the Defendant.
p. 12On 23.11.2023, the Court directed the Defendant to disclose third-party receivables.
p. 12The Defendant filed an affidavit on 07.12.2023, admitting ₹7.42 crores was receivable from Zee Entertainment and ₹2.32 crores was due from films ‘IB-71’ and ‘Bholaa’.
p. 13On 19.12.2023, the Court recorded an undertaking by the Defendant to deposit these "admitted amounts" within two weeks and restrained the release of any films without leave.
p. 14The Plaintiff filed I.A. 815/2024 alleging contempt for: (i) failure to deposit the ₹7.42 crores and ₹2.32 crores within the deadline; and (ii) releasing the web-series ‘Indian Police Force’ and film ‘Crakk’ without Court leave.
p. 3, 402Issues
i.Whether the Defendant's failure to deposit the admitted sums of ₹7.42 crores and ₹2.32 crores within the two-week timeline stipulated in the order dated 19.12.2023 constitutes "wilful disobedience" under the Contempt of Courts Act, 1971.
pp. 16/para.19-21ii.Whether the release of ‘Indian Police Force’ and ‘Crakk’ violated the restraint orders dated 23.11.2023 and 19.12.2023.
p. 20/para.2803Law Applied
The Court primarily applied Order XXXIX Rule 2A of the Code of Civil Procedure, 1908, regarding the consequences of disobedience of an injunction.
p. 1Sections 11 and 12 of the Contempt of Courts Act, 1971, and Article 215 of the Constitution of India, which empower the High Court to punish for contempt.
p. 2The court relied on the principle that an undertaking given to the Court has the same force as an injunction, and "wilful disobedience" involves a deliberate disregard of a clear and unequivocal judicial direction.
p. 19, 23Provisions in the judgment · 2 · Linked ones open on LawLens
Contempt of Courts Act, 1971 Section 11Section 12
04Reasoning
The Court found the direction in the order dated 19.12.2023 to be "unequivocal and clear".
p. 19Regarding the ₹2.32 crores, the Defendant failed to pay within two weeks and raised "unsustainable defences" like set-offs, eventually paying only after multiple subsequent court warnings on 08.05.2025.
pp. 15-16Regarding the ₹7.42 crores, the Court rejected the Defendant’s argument that its liability was contingent on Zee Entertainment making the payment; the Court noted that the Defendant had accepted the two-week deposit deadline without qualification.
¶ 25A shortfall of ₹3.13 crores remains, and the tranches received were delayed.
pp. 17-19Regarding the films, the Court noted a "doubt about the veracity" of the Defendant's claim that its contract for ‘Crakk’ was terminated just after the restraint order, and found its claim of being a mere "line producer" for ‘Indian Police Force’ prima facie negated by its "Producer" credit in the series.
pp. 21-22However, these factual disputes were reserved for trial.
pp. 21-2205Holding
The Court held Respondent Nos. 1, 2, and 3 (Director, Additional Director, and Authorized Representative) guilty of wilful disobedience of the order dated 19.12.2023.
p. 24The Court sentenced them to simple imprisonment for four weeks.
p. 24However, the sentence was suspended for two weeks to allow them to "purge the contempt" by: (i) depositing the balance ₹3.13 crores with 12.5% interest; and (ii) paying 12.5% interest on the delayed payments of ₹4.29 crores and ₹2.32 crores.
pp. 24-25If the payments are made within two weeks, the sentence shall be remitted; otherwise, they must surrender to undergo the term.
p. 25Respondents were directed to furnish bail bonds of ₹1 lakh each before the Joint Registrar on 16.03.2026.
p. 25Original Court PDF
Super Cassettes Industries Private Limited v. Reliance Entertainment Studios Private Limited CS(COMM) 840/2023
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Original judgment, available to read, download and summarize on LawLens.in
