“Babu Ram Gupta v. Sudhir Bhasin, (1980) 3 SCC 47 was clarified and held in part to be obiter by a Three-Member Bench in Rama Narang v. Ramesh Narang, (2006) 11 SCC 114. Rama Narang pointed out, distinction between two categories of cases covered by Section 2(b) of The Contempt of Courts Act, 1971 – (i) wilful disobedience to a process of Court and (ii) wilful breach of an undertaking given to a Court. In fact, in Rama Narang, this Court went to extent of holding, it would neither be in consonance with statute, judicial authority, principle or logic to draw any distinction between wilful violation of terms of a consent decree and wilful violation of a decree passed on adjudication. We have our own doubts whether first category of cases covered by Section 2(b) can be stretched so far. Anyway, that question does not arise in this case and hence we leave it at that.”

– Hon’ble Justice V. Ramasubramanian, Suman Chadha v. Central Bank of India, [Special Leave Petition (Civil) No. 28592 of 2018].

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Also see, Future Coupons Private Limited v. Amazon.Com NV Investment Holdings LLC, [Civil Appeal Nos. 858-860 of 2022] decided on 01.02.2022.