BABU RAM GUPTA vs SUDHIR BHASIN & ANR.

The Supreme Court held that the appellant's failure to hand over possession of property to a receiver, as per a consent order, did not constitute contempt of court under Section 2(b) of the Contempt of Courts Act. The Court clarified that a breach of an undertaking must be explicit and cannot be assumed; thus, without an express undertaking to hand over possession, the appellant's actions, while improper, did not amount to contempt. The judgment emphasized that contempt proceedings must be approached with caution and are meant to protect the integrity of the judicial process, not merely to enforce private agreements.