The petitioner, Binod Agarwal, filed a contempt petition before the Bombay High Court alleging that the Respondents (State of Maharashtra and police officials) wilfully disobeyed directions laid down by the Supreme Court in landmark judgments (Joginder Kumar, Arnesh Kumar, Lalita Kumari) by illegally arresting him without following the procedure under Section 41A of the CrPC in connection with FIR No. 93 of 2018 registered under the IT Act, and detaining him for approximately 65 days. The Respondents contended that all legal procedures were duly followed, that the offence was cognizable, and that the petitioner had voluntarily executed Consent Terms in June 2019 whereby all disputes were amicably resolved and the FIR was quashed by the High Court. The Court found that the sine qua non for civil contempt — wilful disobedience of a court order — was not established, as there was no judicial finding or conclusive adjudication in any prior order that the Respondents had violated the petitioner's rights. The Court noted that the observations in the Supreme Court judgments relied upon were made in the context of those specific cases, and that tangible material and evidence translated into a court order finding such infractions were absent on record.