“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, the 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 the extent of holding, it would neither be in consonance with the statute, judicial authority, principle or logic to draw any distinction between the wilful violation of the terms of a consent decree and wilful violation of a decree passed on adjudication. We have our own doubts whether the 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].