Pre-existing network arrangements and an undefined status quo did not establish wilful disobedience.

Zee Entertainment Enterprise Limited (“Zee”) sought action under Section 20 of the Telecom Regulatory Authority of India Act, 1997 (“TRAI Act”), alleging wilful disobedience of interim orders dated 24 and 27 July 2026.

Those orders directed the respondents to maintain status quo as on 23 July 2026 and restrained them from receiving Zee’s signals from other MSOs, directly or indirectly.

Zee alleged that Lytus Sri Sai Networks Private Limited (“Respondent No. 1”) continued transmitting Zee’s channels through a network associated with GTPL Hathway Limited (“Respondent No. 7”), and relied on website redirection and video recordings as evidence.

GTPL denied taking over Respondent No. 1, stating that it had an arrangement to service subscribers and was not liable for Respondent No. 1’s past dues. Certain directors also denied personal responsibility or wilful disobedience.

The Tribunal found that the alleged migration-related activity and GTPL’s involvement were described as existing or underway before the interim orders; it also noted that GTPL was impleaded only on 27 July 2026.

Zee’s underlying petition claimed ₹14,39,17,332 in unpaid subscription dues against Respondent No. 1.

Section 20 of the TRAI Act provides for fines where a person wilfully fails to comply with an order of the Appellate Tribunal.

Section 19 provides that Tribunal orders are executable as decrees of a civil court.

The Tribunal also referred to the TRAI Act’s provisions concerning its jurisdiction and procedure, and to the Specific Relief Act, 1963, including its framework for preventive relief and injunctions.

It relied on Mahadev Cable Net v. Star India Pvt. Ltd., for the proposition that Tribunal orders should be given effect and that Section 20 may be invoked for deliberate and wilful non-compliance, and on SCOD 18 Networking Pvt. Ltd. v. United Cable Services, concerning available enforcement mechanisms and the exercise of contempt-related powers.

The operative requirement for Section 20 was wilful failure to comply; the Tribunal considered that the evidence did not establish such wilfulness here.

The Tribunal concluded that the interim direction to maintain status quo did not specify the precise factual position to be preserved, while Zee’s own pleadings described subscriber migration and related activity as already underway before the orders were made.

The website redirection and other cited material did not prove that the respondents had wilfully breached the orders; in particular, GTPL’s relevant involvement predated its impleadment on 27 July 2026.

The Tribunal also found no sufficient proof of wilful disobedience by Respondent No. 1 or its directors.

However, because the claimed dues against Respondent No. 1 were not denied and the main petition sought recovery of those dues, the Tribunal considered security measures appropriate to prevent its eventual decision from becoming ineffective.

It nevertheless directed Respondent Nos. 1–6 to file, within three weeks, affidavits undertaking to secure the claimed ₹14,39,17,332, together with any interest awarded, if the amount is decreed in the main petition.

GTPL was stated not to be responsible for Respondent No. 1’s pre-27 July 2026 dues, but the Tribunal directed it to provide details of relevant assets of Respondent No. 1 that it had acquired or taken over after the interim order; Respondent Nos. 1–6 were also directed to specify assets claimed as security.

Non-compliance with these directions would be treated as deliberate defiance and addressed under Section 20.

The miscellaneous application was disposed of on those terms.