Facts
The Plaintiff (SCIPL/T-Series) filed a suit for recovery of approximately ₹60.23 crores under a Loan Agreement dated 19.05.2021.
Source reference: p.2Under the agreement and subsequent amendments, the Plaintiff held a lien on revenues from specific films produced by the Defendant.
Source reference: p.12On 23.11.2023, the Court directed the Defendant to disclose third-party receivables.
Source reference: 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’.
Source reference: 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.
Source reference: 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.
Source reference: p.3, 4Issues
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.
Source reference: p.16/para.19-21Whether the release of ‘Indian Police Force’ and ‘Crakk’ violated the restraint orders dated 23.11.2023 and 19.12.2023.
Source reference: p.20/para.28Law Applied
The Court primarily applied Order XXXIX Rule 2A of the Code of Civil Procedure, 1908, regarding the consequences of disobedience of an injunction.
Source reference: 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.
Source reference: 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.
Source reference: p.19, 23Reasoning
The Court found the direction in the order dated 19.12.2023 to be "unequivocal and clear".
Source reference: 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.
Source reference: p.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.
Source reference: para. 25A shortfall of ₹3.13 crores remains, and the tranches received were delayed.
Source reference: p.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.
Source reference: p.21-22However, these factual disputes were reserved for trial.
Source reference: p.21-22Holding
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.
The Court sentenced them to simple imprisonment for four weeks.
Source reference: 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.
Source reference: p.24-25If the payments are made within two weeks, the sentence shall be remitted; otherwise, they must surrender to undergo the term.
Source reference: p.25Respondents were directed to furnish bail bonds of ₹1 lakh each before the Joint Registrar on 16.03.2026.
Source reference: p.25Original Court PDF
Super Cassettes Industries Private Limited v. Reliance Entertainment Studios Private Limited CS(COMM) 840/2023
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