Highlights:

Corporate Brief

• RBI circular for master direction – Reserve Bank of India (Access Criteria for NDS-OM) Directions, 2025.
• RBI notification on Foreign Exchange Management (Manner of Receipt and Payment) (Amendment) Regulations, 2025.
• MCA notification on Companies (Prospectus and Allotment of Securities) Amendment Rules, 2025.
• RBI circular for direction- RBI (Prudential Regulations on Basel III Capital Framework, Exposure Norms, Significant Investments, Classification, Valuation and Operation of Investment Portfolio Norms and Resource Raising Norms for All India Financial Institutions) Directions, 2023 – Amendment.
• RBI notification for Reserve Bank of India (Forward Contracts in Government Securities) Directions, 2025.
• SEBI circular on Regulatory framework for Specialized Investment Funds (‘SIF’).

RERA Brief

• Office Order bearing no. 1411 dated 18.02.2025 issued by the U.P Real Estate Authority (“UP RERA”) laying down the standard operating procedure for extension of registration of real estate projects registered with UP RERA.
• Office Order bearing no. F.1(31)RJ/RERA/AUTHORITY MEETING/2019/166 dated 24.02.2025 issued by the Rajasthan RERA requiring the submission of CC/OC in exemption matters other than plotted schemes.
• Office Order bearing no. F.1(31)RJ/RERA/AUTHORITY MEETING/2019/163 dated 24.02.2025 issued by the Rajasthan RERA stating the requirement of proof of competent authority where no plots have been mortgaged in the plotted schemes.
• Office Order bearing no. F.1(31)RJ/RERA/AUTHORITY MEETING/2019/167 dated 24.02.2025 issued by the Rajasthan RERA providing for the Registration of the Hotel projects where units are sold and leased back.
• Office Order BEARING NO. 70 dated 25.02.2025 issued by the Bihar RERA stipulating the display of QR Code in advertisements and prospectus by Promoters and Real Estate Agents registered with Bihar RERA. 

Intellectual Property Rights Brief: 

• Delhi HC orders removal of the trademark “ZEPTO” registered in the name of Mohammad Arshad.
• Relocation of the CGPDTM Headquarters from Mumbai to Delhi, India.
• Introduction of “Queue of Show Cause Hearing Notice Issuance” for Trade Marks. 

NCLT Brief:  

• Whether penalty under Section 65 of the Code be imposed on the promoters of the corporate debtor in addition to the financial creditors who have initiated CIRP?

Litigation Brief:  

• Contempt Jurisdiction and Disobedience of Undertakings: A Reaffirmation of Court’s Authority. 

Corporate Brief: 

Circular No. RBI/FMRD/2024-25/127 dated 07.02.2025 of the Reserve Bank of India (RBI): 

• Master Direction – Reserve Bank of India (Access Criteria for NDS-OM) Directions, 2025

In exercise of the powers conferred under section 45W of the Reserve Bank of India Act, 1934 (hereinafter called the Act) read with section 45U of the Act, the Reserve Bank of India (“RBI”) has issued the said directions, in supersession of Reserve Bank of India (Access Criteria for NDS-OM) Directions, 2024, dated October 18, 2024.

Before the said direction, the entities eligible to access the Negotiated Dealing System – Order Matching (“NDS-OM”) were Licensed Banks, Primary Dealers authorized by the RBI, financial institutions as defined in terms of Section 45-I (c) (ii) of the Reserve Bank of India Act, 1934, Central Government, State Governments, Insurance Companies regulated by Insurance Regulatory and Development Authority, Mutual Funds regulated by Securities and Exchange Board of India,  Provident and Pension Funds and Pension Fund Managers, Foreign Central Banks with prior approval of the Bank, Depositories as defined under the Depositories Act 1996, Stock Holding Corporation of India (SHCIL), and the clients of banks and standalone primary dealers.

Under the said direction, RBI has revised access norms for the NDS-OM platform, now permitting Securities and Exchange Board of India (“SEBI”)-registered non-bank brokers to facilitate retail investor trades in Government securities to widen the access. The amendment aims to facilitate liquidity through the participation of retail investors in the government securities market by enabling brokers to execute trades on their behalf.

Circular No. FEMA 14(R)(1)/2025-RB dated 10.02.2025 of the Reserve Bank of India (RBI): 

• Foreign Exchange Management (Manner of Receipt and Payment) (Amendment) Regulations, 2025

In exercise of the powers conferred by section 47 of the Foreign Exchange Management Act, 1999 (42 of 1999), the RBI has issued the Foreign Exchange Management (Manner of Receipt and Payment) (Amendment) Regulations, 2025 (“Amendment Regulation”), which have come in force from 10.02.2025.

The Amendment Regulation amends regulation 3 of Foreign Exchange Management (Manner of Receipt and Payment) Regulations, 2023 notified vide Notification No. FEMA 14(R)/2023-RB dated 20.12.2023. The Amendment Regulation specifies that transactions between residents of Asian Clearing Union (ACU) member countries, excluding Nepal and Bhutan, must be conducted through the ACU mechanism or in accordance with directions issued by the RBI to authorized dealers. This ensures a standardized payment settlement process for ACU member nations (excluding Nepal and Bhutan).

Notification number G.S.R. 131(E) dated 12.02.2025 of the Ministry of Corporate Affairs (MCA): 

• Companies (Prospectus and Allotment of Securities) Amendment Rules, 2025

In exercise of the powers conferred by section 26, sub-section (1) of section 27, section 28, section 29, sub-section (2) of section 31, sub-sections (3) and (4) of section 39, sub-section (6) of section 40 and section 42 read with section 469 of the Companies Act, 2013, the Ministry of Corporate Affairs (“MCA”) has issued the Companies (Prospectus and Allotment of Securities) Amendment Rules, 2025, (“Amendment Rules”) which have come in force from 12.02.2025.

Under the Amendment Rules, MCA has extended the deadline for private limited companies to comply with the mandatory dematerialization requirements. This extension applies to private companies other than producer companies whose financial year ended on March 31, 2023, which is not a small company. The revised compliance deadline is now June 30, 2025.

Notification Number RBI/2024-25/116 dated 02.2025 of the Reserve Bank of India (RBI):

• Reserve Bank of India (Prudential Regulations on Basel III Capital Framework, Exposure Norms, Significant Investments, Classification, Valuation and Operation of Investment Portfolio Norms and Resource Raising Norms for All India Financial Institutions) Directions, 2023.

In exercise of the powers conferred under section 45L of the Reserve Bank of India Act, 1934 (hereinafter called the Act), the RBI has issued the said notification to amend Master Direction – Reserve Bank of India (Prudential Regulations on Basel III Capital Framework, Exposure Norms, Significant Investments, Classification, Valuation and Operation of Investment Portfolio Norms and Resource Raising Norms for All India Financial Institutions) Directions, 2023 (‘Master Direction”).

The said notification has amended paragraph 34.2.3 of the Master Direction, which restricts All India Financial Institutions (“AIFIs”) from investing more than 25 percent of their investment under the Held to Maturity (“HTM”) category.

Notification Number FMRD.DIRD.16/14.03.042/2024-25 dated 21.02.2025 of the Reserve Bank of India (RBI):

• Reserve Bank of India (Forward Contracts in Government Securities) Directions, 2025

In exercise of the powers conferred under section 45W of the Reserve Bank of India Act, 1934, (hereinafter called the Act) read with section 45U of the Act, the RBI on 21.02.2025 has issued Reserve Bank of India (Forward Contracts in Government Securities) Directions, 2025 (“Forward Contracts Direction”) which shall take effect from 02.05.2025.

The Forward Contracts Direction allows for bond forward contracts in government securities and sets out the framework to enable market participants, especially long-term investors, to deal in such instruments. The Forward Contract Direction amend Gazette Notification (S.O. 2192 (E) dated 8th January 2010) which prohibited all forms of sale and purchase contracts in government securities other than (i) spot delivery contracts; and (ii) contracts traded on recognized stock exchanges. Now, the RBI permits various forms of sale and purchase contracts in government securities that are approved by it from time to time.

Circular Number SEBI/HO/IMD/IMD-PoD-1/P/CIR/2025/26 dated 27.02.2025 of Securities and Exchange Board of India: 

• Regulatory framework for Specialized Investment Funds (‘SIF’)

In the exercise of the powers conferred by Section 11(1) of the Securities and Exchange Board of India Act, 1992 read with Chapter VI-C of the SEBI (Mutual Funds) Regulations 1996, the SEBI has issued the said circular to set out the regulatory framework for Specialized Investment Funds (“SIF”). The framework aims to bridge the gap between Mutual Funds (MFs) and Portfolio Management Services (PMS) by providing enhanced portfolio flexibility. The said circular outlines eligibility criteria, branding requirements, investment strategies, and operational guidelines for SIFs. It sets a minimum investment threshold of ₹10 lakh per investor and specifies investment restrictions, derivative exposure limits, and redemption policies. The framework includes risk assessment mechanisms, disclosure norms, and compliance requirements for asset management companies (AMCs), stock exchanges, clearing corporations, and depositories.

RERA Brief:

Office Order bearing no. 1411 dated 18.02.2025 issued by the U.P Real Estate Authority (“UP RERA”) laying down the standard operating procedure for extension of registration of real estate projects registered with UP RERA. 

• Vide the office order dated 18.02.2025 UP RERA has revised standard operating procedure for extension of real estate projects.
• As per the said office order, the revised standard operating procedure for extension of registration of real estate projects is as follows:

1. Submission of Application for Extension of Registration: The promoter is required to submit the application in the prescribed form atleast 3 (three) months prior to the expiry of the registration granted. The promoter who fails to submit the application in time which is required to deposit the fees for the delay, in addition to the fees prescribed under rules.
2. Details to be submitted: Alongwith the application requisite details are to be submitted including inter alia basic project details, valid sanctioned plan, status of physical, financial and miscellaneous QPRs, status of annual report on statement of accounts, etc. in case the extension of registration is sought for beyond one year, then additional documents required to be submitted along with the application, such as consent of the allottees, association of allottees, NCLT Order and Resolution Plan (if applicable), Affidavit, Sources of Finance and late fee of Rs. One Lakh is required to be deposited in addition to fee prescribed under Rules.

• Evaluation of Extension Application: The application for extension is to be evaluated and reviewed by the technical division of the authority. The Technical Division is to examine the application and prepare a checklist in the prescribed format. For extension beyond the time limit, the Technical Division is required to assess the project on legal viability, economic viability, operational viability, and project oversight by AoA.

1. Disposal of Application: The certificate of extension of registration is to be issued by the Secretary in prescribed format, after the approval of the authority. After giving due opportunity of hearing, the intimation of the rejection of the extension is to be issued in prescribed form. The promoter may re-apply after rejection be paying the requisite fee and rectifying the grounds of rejection.
2. Activities and Extension of Registration: The promoter is required to submit a copy of the physical and financial plan for completion of the balance work of the Project at the end of every quarter along with the QPRs in the prescribed format. For Authority, in all cases of extension of registration the extended period shall be shown with the name of the project and, such projects shall be shifted under the category of “Projects Extended Beyond Scope of Section 6” list on the U.P. RERA Web Portal immediately after issuing the certificate of extension of registration. In case a promoter continues to default on the progress of the project for two consecutive quarters, the Secretary, U.P. RERA shall place the matter before the Authority for review and appropriate action as per the provisions of the Act, Rules and Regulations.
3. For further details the link to the notification dated 18.02.2025 is as follows: https://www.up-rera.in/pdf/projectexpension1411.pdf.

Office Order bearing no. F.1(31)RJ/RERA/AUTHORITY MEETING/2019/166 dated 24.02.2025 issued by the Rajasthan Real Estate Regulatory Authority (“Rajasthan RERA”) requiring the submission of CC/OC in exemption matters other than plotted schemes.

• Vide the office order dated 24.02.2025 Rajasthan RERA directed that promoter seeking exemption of projects other than plotted schemes shall submit the Occupancy Certificate along with the Completion Certificate at the time of filing of such application.

Office Order bearing no. F.1(31)RJ/RERA/AUTHORITY MEETING/2019/163 dated 24.02.2025 issued by the Rajasthan RERA stating the requirement of proof of competent authority where no plots have been mortgaged in the plotted schemes.

• Vide the office order dated 24.02.2025 Rajasthan RERA has provided for the requirement of proof of competent authority where no plots have been mortgaged in the plotted schemes.
• RERA Rajasthan through its order dated 24.05.2023 mandated that promoters must provide proof from the Local Body confirming that no plots are mortgaged in an approved layout. This proof can be a letter from the Local Body or a copy of an RTI application for getting a certificate that plots were not mortgaged in the schemes.
• However, under Regulation 13(5)(i) of the Rajasthan Real Estate Regulatory Authority Regulations, 2024, as proof an “undertaking” of the promoter that no plots have been mortgaged in the scheme is required.
• Affirming the order dated 24.05.2023, Rajasthan RERA directed that the promoters shall have to submit the proof of Local Authority/ RTI as mandated in the said order.

Office Order bearing no. F.1(31)RJ/RERA/AUTHORITY MEETING/2019/167 dated 24.02.2025 issued by the Rajasthan RERA providing for the Registration of the Hotel projects where units are sold and leased back.

• Vide the office order dated 24.02.2025 Rajasthan RERA has provided for the Registration of the Hotel projects where units are sold and leased back.
• The Rajasthan RERA through this order has clarified and mandated that such Hotel projects where sale deeds have been executed in favor of the purchaser/ allottee for a unit and the same has been leased back to the developer, are necessarily required to be registered under RERA Act.

Office Order BEARING NO. 70 dated 25.02.2025 issued by the Bihar RERA stipulating display of QR Code in advertisements and prospectus by Promoters and Real Estate Agents registered with Bihar RERA.

• Vide the office order dated 25.02.2025 Bihar RERA has provided for the display of QR Code in advertisements and prospectus by Promoters and Real Estate Agents registered with Bihar RERA.
• The Authority has provided QR codes to all the registered real estate projects to help prospective home/plot/shop buyers get project-related information easily so that buyers can make informed decisions.
• RERA Bihar through this order mandates that promoters and real estate agents must prominently display the QR code of registered projects in advertisements, social media campaigns, brochures, booking forms, allotment letters, and display boards at project sites. The QR code should be placed beside the project registration number and website address for easy access to project details.
• The real estate agent, facilitating sale of any apartment, plot, office space, shops or building etc. in any real estate project would provide details related to the project along with its registration certificate and QR code to the buyer.
• The order further prescribes that failure to comply with the directions would attract penal action, under relevant provisions of the RERA Act.
• For further details the link to the notification dated 25.02.2025 is as follows: https://rera.bihar.gov.in/images/QR%20Code%20in%20advertisement.pdfhttps://rera.bihar.gov.in/images/QR%20Code%20in%20advertisement.pdf.

IPR Brief:

Delhi HC orders removal of the trademark “ZEPTO” registered in the name of Mohammad Arshad.

 Kiranakart Technologies Private Limited v/s Mohammad Arshad & Anr. (2025 SCC OnLine Del 1401) 

In the High Court of Delhi at New Delhi (before J. Amit Bansal, J.)

Decided on March 3, 2025

Facts of the case

A rectification petition was filed under Sections 47 and 57 of the Trade Marks Act, 1999 (hereinafter ‘the Act’) seeking cancellation/removal of the trade mark ‘ZEPTO’ bearing no. 2773519 in class 35 in the name of the respondent no. 1 (hereinafter ‘impugned mark’) from the Register of Trade Marks.

The petitioner, provides delivery service through a mobile application, under the mark ZEPTO and variations of the mark (hereinafter collectively referred to as ‘ZEPTO marks’). The petitioner commenced its business under the ZEPTO marks in July 2021. The petitioner has obtained trade mark registrations for the ZEPTO marks in classes 29, 30, 31, 32, 34, 39 and 43.

The respondent no. 1 had filed a trademark application for the mark ZEPTO in classes 9 and 35 on 14th July, 2014 with a user claim of April 01, 2011 and attained registration. The services in class 35 read as ‘advertising, export & import, wholesale & retail outlets and shops including services relating to distribution, trading and marketing of mobile phones; mobile internet devices; mobile phone parts & accessories; smart phones; microphones; headsets; batteries; speakers; phone chargers; chips for mobiles, mobile gaming device and accessories, portable communication gazettes & devices; computer software and telecommunication apparatus to enable access to databases and internet; services; wi-fi routers; telephone instruments and devices, technical consultancy”.

The respondent no. 1 had filed a Notice of Opposition against the Petitioner’s trade mark application bearing no. 5079706 for the mark ZEPTO in class 35. Aggrieved by the same, the Petitioner filed the subject rectification petition.

Analysis and Findings of the Court

As per the Court’s findings, the respondent did not file its reply to the petition. Per the Court’s findings, in the absence of any denial of the averments made in the petition, the same have to be taken as admitted and as such, the averments made in the petition were deemed to be admitted.

The petitioner, in the present case, had filed an affidavit of the authorized representative of an independent investigating agency to support its averments with regard to non-use of the impugned mark by the respondent no. 1 for the claimed services in class 35 for nearly 8 years up to the date of filing of the present petition.

The petitioner established a use of July 2021 for its ZEPTO marks in India while the respondent no. 1 was not able to show any use of the impugned mark in relation to the claimed services in class 35. Despite this, the respondent no.1 opposed the petitioner’s application for the mark ZEPTO in class 35.

Considering the aforesaid, the Court was of the view that the petitioner is aggrieved by the existence of the impugned mark on the Register of Trade Marks.

Accordingly, the impugned mark was held liable to be removed from the Register of Trade Marks under the provisions of Section 47(1) (b) of the Act. The petition was allowed and the Trade Marks Registry was directed to remove the impugned mark ‘ZEPTO’ bearing the no. 2773519 in class 35 in the name of the respondent no. 1 from the Register of Trade Marks.

Relocation of the CGPDTM Headquarters from Mumbai to Delhi, India.

The Ministry of Commerce and Industry, Government of India has published a notification dated 25.02.2025 that the Office Of The Controller General Of Patents, Designs and Trade Marks (CGPDTM) headquarters shall be moved to New Delhi at the following address:

Controller General of Patents, Designs and Trade Marks, Office of Controller General of Patents, Designs and Trade Marks,

Boudhik Sampada Bhawan, Plot No. 32, Sector 14, Dwarka, New Delhi-110078. 

Introduction of “Queue of Show Cause Hearing Notice Issuance” for Trade Marks. 

The Office Of the Controller General Of Patents, Designs And Trade Marks (CGPDTM) has introduced the “Queue of Show Cause Hearing Notice Issuance” feature on the Trade Marks Registry’s official website www.ipindia.gov.in.

This initiative will help stakeholders stay informed about the status of their respective matters. 

NCLT Brief:

Whether penalty under Section 65 of the Code be imposed on the promoters of the corporate debtor in addition to the financial creditors who have initiated CIRP?

Facts of The Case

An application under Section 7 of the Insolvency and Bankruptcy Code (“Code”) was filed by a total of six financial creditors of the corporate debtor, namely, M/s. Sharp Eye Advertising Private Limited. Vide the order dated 17.05.2022, the Hon’ble NCLT admitted the Section 7 application and initiated Corporate Insolvency Resolution Process (“CIRP”) proceedings against the corporate debtor.

After the initiation of CIRP, an application was filed by one, Rockman Advertising and Marketing (India) Limited (“Rockman”), who claimed to be the majority shareholder of the corporate debtor. It was contended by Rockman that the Section 7 application was filed fraudulently with malicious intent by the financial creditors in collusion with the corporate debtor and its directors/promoters. It was also submitted by Rockman that presentation of  Section 7 application was a measure by the corporate debtors and/or its promoters to evade their liability under an oppression and mismanagement petition filed by Rockman against the corporate debtor in 2013.

Vide the order dated 12.06.2024 (“Impugned Order“), the Hon’ble NCLT recalled the order dated 17.05.2022, whereby CIRP proceedings of the corporate debtor were initiated, and a Show Cause Notice was issued to the financial creditors to show as to why a penalty as stipulated under Section 65(1) of the Code should not be imposed on them.

Aggrieved by the Impugned Order passed by the Hon’ble NCLT, two appeals were filed before the Hon’ble NCLAT seeking modification of the Impugned Order to extend that the penalty under Section 65 of the Code may also be be imposed over the promoters of corporate debtor in addition to the financial creditors. Further, it was prayed that a penalty of INR 1 Crore under Section 65(1) of the Code be imposed each on the financial creditors as well as the promoters of the corporate debtor as the Hon’ble NCLT did not impose any penalty.

Findings of The Hon’ble NCLAT

1. Whether penalty u/s 65 of the Code be imposed on the promoters of the corporate debtor in addition to the financial creditors who have initiated the CIRP proceedings?

The Hon’ble NCLAT noted that the use of expression “impose upon such person a penalty” in sub-section (1) of Section 65 of the Code  relates to the person who has initiated the insolvency resolution process. Further, Section 65 being a penal provision, is required to be strictly construed and it was observed that no interpretation can be put on the provisions of Section 65 that penalty can be imposed on any other person except those who have initiated insolvency resolution process fraudulently or maliciously. Therefore, it was held that the promoters of the corporate debtor are not to be penalized under Section 65 of the Code.

2. Whether NCLT can issue a Show Cause Notice under Rule 59 of the NCLT Rules, 2016 for imposing penalty under Section 65 of the Code?

In the present case the show cause notice was issued to the financial creditors only. The Hon’ble NCLAT observed that that Rule 59 of the NCLT Rules, 2016 only provides for procedure for imposition of penalty under the Companies Act, 2013. Show Cause Notice under Rule 59 is not required while imposing a penalty under Section 65 of the Code and is strictly confined to the procedure while imposing penalty under Companies Act 2013.

The Hon’ble NCLAT held that prayers of the Appellants for modification of the Impugned Order  and imposition of the penalty cannot be accepted and therefore, the appeals were dismissed. Further, it was held that it was open to NCLT to pass appropriate order with regard to penalty under Section 65 on the financial creditors.

Case referred: Rakesh Arora & Anr. v. Acute Daily Media Pvt. Ltd. & Ors. [Company Appeal (AT) (Insolvency) No. 1608 of 2024]

Litigation Brief

Contempt Jurisdiction and Disobedience of Undertakings: A Reaffirmation of Court’s Authority

• CASE ANALYSIS: Lavanya C & Anr. vs. Vittal Gurudas Pai (Deceased) by LRs & Ors

Decided by double bench consisting of Justice Pankaj Mithal and Justice Sanjay Karol of the Hon’ble Supreme Court of India on 05.03.2025.

Factual Matrix:

1. This appeal arises out of judgment and order dated 23^rd February 2021/ 16^th March, 2021, passed by the High Court of Karnataka at Bengaluru, whereby the respondents before the High Court (Appellants herein) were held guilty of disobedience of their undertaking before the Trial Court of not alienating the property, subject matter of the suit.
2. The Respondents herein were the original Plaintiffs in Original Suit No. 4191 of 2007, seeking a declaration to the effect that agreement between the parties dated 30^th April, 2004, i.e., Joint Development Agreement (JDA) to be revoked rescinded and terminated. The JDA period was entered into regarding the construction of residential apartments within a period of 24 months.
3. The Plaintiffs (respondents) claimed that the construction was not completed by the stipulated date, that being, 31^st October, 2006, and issued a legal notice cancelling the JDA on 23^rd March, 2007.
4. Plaintiffs filed Original Suit No. 4191 of 2007, seeking declaration that the JDA stood revoked, rescinded, and terminated.
5. During the suit’s pendency:
   1. The Defendants (Appellants herein), through their counsel, gave undertakings not to alienate the suit property (on 11th July and 13th August 2007).
   2. Despite these undertakings and subsequent court orders, the Defendants sold portions of the property, leading to allegations of contempt.
6. The Trial Court (2017) ruled against the plaintiffs, holding they failed to prove violations of the JDA, and dismissed their suit.
7. However, the Plaintiffs filed a contempt application under Order XXXIX Rule 2A CPC, alleging wilful disobedience of the defendants’ undertaking.
8. The Trial Court (2013) dismissed this contempt application, granting the appellants the benefit of the doubt.

Key Issues:

1. Whether the defendants (appellants) wilfully disobeyed the undertaking and injunction order not to alienate the property?
2. Whether the High Court was justified in overturning the Trial Court’s finding and holding the appellants guilty of contempt?
3. Whether contempt jurisdiction was rightly invoked, and whether the sentence imposed was proportionate?

Observations of the Supreme Court:

1. On the Disobedience of the Undertaking:

• The undertaking was voluntarily given by the Appellants’ counsel in July and August 2007, and later formalized by the Trial Court in November 2007.
• Despite this, multiple sale deeds were executed by the appellants, violating the order.
• The appellants’ argument that their counsel lacked authority to provide the undertaking was rejected. A lawyer-client relationship is fiduciary, and any such act requires client authorization.

2. On Order XXXIX Rule 2A CPC:

• The Court reaffirmed that subsequent setting aside of the injunction order does not absolve liability for its prior violation (Samee Khan v. Bindu Khan (1998) 7 SCC 59 relied upon).
• Disobedience of an interim order remains punishable, even if the underlying suit is dismissed later.

3. On Contempt Jurisdiction:

• Contempt powers aim to uphold the dignity and authority of the Court.
• The High Court’s action in holding the appellants guilty of contempt was justified.
• However, considering the age and health of one appellant, the Supreme Court modified the punishment:
• Deleted the three-month civil imprisonment.
• Maintained attachment of property.
• Enhanced compensation from ₹10 lakhs to ₹13 lakhs, payable with 6% simple interest from 2nd August 2013.

Final Decision:

• Appeal partly allowed.

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