Failure to deposit admitted amounts within court-mandated timelines constitutes wilful disobedience and actionable contempt.

The Plaintiff (SCIPL/T-Series) filed a suit for recovery of approximately ₹60.23 crores under a Loan Agreement dated 19.05.2021.

Under the agreement and subsequent amendments, the Plaintiff held a lien on revenues from specific films produced by the Defendant.

On 23.11.2023, the Court directed the Defendant to disclose third-party receivables.

The 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’.

On 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.

The 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.

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.

Whether the release of ‘Indian Police Force’ and ‘Crakk’ violated the restraint orders dated 23.11.2023 and 19.12.2023.

The Court primarily applied Order XXXIX Rule 2A of the Code of Civil Procedure, 1908, regarding the consequences of disobedience of an injunction.

Sections 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.

The 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.

The Court found the direction in the order dated 19.12.2023 to be "unequivocal and clear".

Regarding 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.

Regarding 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.

A shortfall of ₹3.13 crores remains, and the tranches received were delayed.

Regarding 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.

However, these factual disputes were reserved for trial.

The Court sentenced them to simple imprisonment for four weeks.

However, 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.

If the payments are made within two weeks, the sentence shall be remitted; otherwise, they must surrender to undergo the term.

Respondents were directed to furnish bail bonds of ₹1 lakh each before the Joint Registrar on 16.03.2026.