PepsiCo Case: Delhi HC on Wilful Disobedience

PepsiCo Case: Delhi HC on Wilful Disobedience. In commercial litigation, interim injunctions are often the most critical stage of a dispute. They aim to preserve rights and prevent ongoing harm until the final adjudication. However, the real challenge arises not in granting such orders, but in ensuring their effective enforcement.
The Delhi High Court’s decision in Pepsico Inc. & Anr. v. Parle Agro Pvt. Ltd. (2026) provides important clarity on this issue. The case revolves around alleged violations of an earlier injunction concerning the use of the tagline “For The Bold” and raises a fundamental question:
When does non-compliance with a court order become “wilful disobedience” warranting penal consequences?
The judgment offers a nuanced answer by distinguishing between deliberate defiance and inadvertent lapse, thereby shaping the contours of enforcement under Order XXXIX Rule 2A of the Code of Civil Procedure, 1908 (CPC).
Background of the Dispute
The dispute originated from a trademark and passing off claim filed by PepsiCo Inc., alleging that Parle Agro Pvt. Ltd. had infringed its registered tagline “For The Bold.”
In the earlier stage of the litigation, the Delhi High Court, through its order dated 18 September 2023, granted limited injunctive relief. Importantly, the Court did not impose a blanket prohibition on the use of the tagline. Instead, it crafted a balanced and conditional order, allowing certain uses while restricting others.
The directions included:

Restricting modification of product labels without prior approval

Prohibiting the use of “For The Bold” as the dominant element in advertising campaigns

Directing the removal of specific advertisements on social media platforms

Requiring the defendant to periodically disclose sales revenue data

This calibrated approach reflected the Court’s attempt to balance trademark rights with commercial freedom.
Trigger for the Present Proceedings
The present proceedings were initiated when PepsiCo approached the Delhi High Court by filing an application under Order XXXIX Rule 2A of the Code of Civil Procedure, 1908, alleging that Parle Agro had failed to comply with the earlier interim injunction order dated 18 September 2023. This provision empowers the Court to take action in cases where a party is accused of disobeying or breaching an injunction, and may even lead to penal consequences such as attachment of property or civil imprisonment.
PepsiCo’s application was not based on a single isolated instance but on what it described as a pattern of continued non-compliance, which, according to the plaintiff, undermined both its trademark rights and the authority of the Court. The allegations were structured around two primary grounds:
Continued Display of Advertisements
PepsiCo alleged that despite the Court’s clear direction to take down advertisements featuring the tagline “For The Bold”, certain promotional content remained accessible on the defendant’s social media platforms, particularly:

X (formerly Twitter)

Instagram

These platforms, being widely used for brand promotion, were considered crucial channels through which the allegedly infringing tagline continued to reach consumers. PepsiCo argued that even if the number of such posts was limited, their continued availability in the public domain amounted to an ongoing breach of the Court’s order.
The plaintiff emphasised that compliance with an injunction is not partial but must be complete and effective. Therefore, the mere existence of even a few posts containing the prohibited tagline indicated that the defendant had not fully adhered to the Court’s directions. It was further argued that in the digital age, where content can be accessed and shared instantly, failure to remove such posts could result in continued commercial advantage and consumer confusion, thereby defeating the purpose of the injunction.F
Non-Compliance with Financial Disclosure
The second and more serious allegation related to the defendant’s failure to comply with the Court’s direction to periodically file sales revenue certificates associated with the use of the impugned tagline.
The earlier order had specifically required Parle Agro to:

Submit sales revenue data every two months

Cover the period from the commencement of the use of the label containing “For The Bold”

PepsiCo contended that this requirement was not merely procedural but served an important purpose, namely:

To monitor the extent of commercial benefit derived from the use of the tagline

To assist the Court in determining damages or profits at a later stage

However, the defendant had allegedly failed to comply with this direction for over two years, without providing any satisfactory explanation. The plaintiff argued that such prolonged non-compliance could not be dismissed as a mere oversight. Instead, it reflected a deliberate disregard for judicial directions.
PepsiCo characterised this conduct as:

Continuous – extending over a significant period

Unexplained – lacking any reasonable justification

Contemptuous – showing indifference to the authority of the Court

According to the plaintiff, this failure struck at the very root of judicial discipline, as it suggested that parties could selectively comply with orders based on their own assessment of relevance or convenience.
Defendant’s Response
Parle Agro contested the allegations in their entirety and sought to present the issue not as one of intentional or wilful violation, but as a case of inadvertent and unintentional non-compliance. The defence was structured to demonstrate that the defendant had acted in good faith, had substantially complied with the Court’s earlier directions, and that any lapse was minor, accidental, and promptly corrected once brought to its notice.
Its response rested on the following key arguments:
No Fresh Violation
At the outset, the defendant emphasised that it had fully respected the spirit of the Court’s injunction by refraining from issuing any new advertisements using the tagline “For The Bold” after the order dated 18 September 2023.
It was argued that:

The injunction did not impose a blanket prohibition on all past usage, but was primarily directed at preventing continued or future misuse.

The defendant had not launched any fresh marketing campaign or promotional material in violation of the order.

By highlighting the absence of any new infringing conduct, the defendant sought to demonstrate that it had acted in compliance with the Court’s directions and had not attempted to circumvent or undermine the injunction.
Legacy Content on Social Media
With respect to the advertisements cited by the plaintiff, the defendant clarified that these were old social media posts dating back to 2022, i.e., prior to the passing of the injunction order.
The continued presence of these posts was attributed to practical and operational challenges, including:

Oversight – Given the large volume of content managed by the company’s marketing teams, a few posts were inadvertently missed during the removal process.

Volume of Digital Content – The defendant maintained multiple social media accounts with hundreds of posts and campaigns, making complete and immediate tracking of every instance difficult.

Technical and Logistical Difficulties – Locating and removing older or archived posts across platforms can involve technical limitations and delays, especially where content is spread across different accounts or formats.

The defendant argued that such factors are inherent in managing large-scale digital marketing operations and that the omission was neither deliberate nor strategic. It further emphasised that the posts in question were buried within older content and were unlikely to generate any significant commercial benefit.
Immediate Rectification
A key plank of the defence was the assertion of prompt corrective action. The defendant submitted that:

As soon as it became aware of the existence of the remaining posts—through the present application—it immediately removed or took down the content.

This conduct demonstrated its bona fide intention to comply with the Court’s directions.

The defendant argued that such prompt action should be viewed as evidence of good faith and respect for judicial orders, rather than as an admission of wrongdoing. It further suggested that if the plaintiff had informed it earlier about the presence of such posts, the issue could have been resolved without the need for litigation.
Revenue Disclosure Not Urgent
On the issue of non-filing of sales revenue data, the defendant sought to minimise the significance of the alleged breach.
It argued that:

The requirement to file sales revenue certificates every two months was primarily relevant at the stage of determining damages or profits, which would arise only during trial.

At the current stage of proceedings—where issues were yet to be framed and evidence had not commenced—the absence of such data did not cause any immediate or tangible prejudice to the plaintiff.

The defendant further contended that:

The delay in filing the data was not wilful or deliberate, but rather a procedural lapse.

The necessary financial records were maintained and available, and could be produced when required by the Court.

By framing the issue in this manner, the defendant attempted to argue that the non-compliance was technical rather than substantive, and therefore should not attract penal consequences under Order XXXIX Rule 2A CPC.
Issues Before the Court
The Court narrowed the controversy into two distinct questions:

Whether the continued presence of advertisements amounted to wilful disobedience

Whether failure to file sales revenue data constituted serious non-compliance

At the heart of both issues lay the interpretation of “wilful disobedience” under Order XXXIX Rule 2A CPC.
Court’s Analysis
Non-Removal of Advertisements
The Court first examined the issue of the allegedly infringing advertisements.
It noted certain inconsistencies in the defendant’s affidavits, particularly regarding whether the posts were on its own accounts or third-party platforms.
However, the Court did not treat these inconsistencies as decisive. Instead, it focused on the intent behind the conduct.
Key observations included:

The posts were dated 2022, prior to the injunction

The defendant had taken down most offending content

Only a small number of posts remained

The Court accepted the explanation that the omission was due to oversight rather than deliberate defiance.
Finding
The Court held that:

The conduct did not amount to wilful disobedience

Penal action under Order XXXIX Rule 2A CPC was not warranted

Failure to File Sales Revenue Data
On this issue, the Court adopted a markedly stricter approach.
The direction to file revenue data was:

Clear

Specific

Time-bound

Despite this, the defendant had failed to comply for over two and a half years.
The Court rejected the defendant’s argument that:

The data was not immediately relevant

Delay caused no prejudice

Instead, it emphasised a fundamental principle:
Parties cannot decide the importance of a court’s direction—compliance is mandatory.
The Court observed that such non-compliance undermines:

The authority of the Court

The integrity of judicial proceedings

The Legal Standard: What is “Wilful Disobedience”?
A central contribution of the judgment is its clarification of the term “wilful disobedience.”
The Court held that:

Wilful disobedience requires intentional and conscious violation

Mere negligence or oversight is insufficient

The standard is high because the consequences are penal in nature

This interpretation aligns with the Supreme Court’s view that proceedings under Order XXXIX Rule 2A are quasi-criminal, and therefore require strict proof.
Relief and Directions
While the Court declined to impose penal consequences for the advertisement issue, it took serious note of the financial disclosure violation.
The Court ordered:

Imposition of Costs: A cost of Rs.10,00,000 was imposed on the defendant, payable to the “Bharat Ke Veer” fund.

Apology Requirement: The deponent of the affidavits was directed to tender an unconditional apology.

Emphasis on Compliance: The Court reiterated that its orders must be followed in both letter and spirit.

Significance of the Judgment
Clear Threshold for Wilful Disobedience 
The judgment draws a clear line between:

Deliberate violation (punishable)

Inadvertent lapse (not punishable)

This provides much-needed clarity in enforcement proceedings.
Strengthening Judicial Authority 
By imposing costs despite the absence of wilfulness, the Court reinforced that:

Non-compliance has consequences

Judicial orders must be taken seriously

Digital Compliance Challenges 
The case highlights practical challenges in ensuring compliance in the digital ecosystem, where:

Content persists across platforms

Legacy posts may remain unnoticed

Accountability in Commercial Litigation 
The decision underscores that large corporations must maintain robust compliance mechanisms, especially when subject to court orders.
Broader Implications
The judgment has implications beyond the immediate dispute:

It guides how courts will approach social media compliance

It sets standards for corporate accountability

It reinforces the importance of procedural discipline in litigation

Conclusion
The Delhi High Court’s ruling in Pepsico Inc. v. Parle Agro Pvt. Ltd. stands as a carefully balanced and thoughtfully reasoned decision that reconciles two competing considerations—fairness to litigants and strict enforcement of judicial orders. The Court consciously avoided adopting a rigid or overly punitive approach, and instead undertook a nuanced examination of the nature of the alleged non-compliance.
In doing so, the judgment recognises an important practical reality of modern commercial litigation: not every lapse in compliance necessarily amounts to a legal violation, and even where a violation is established, it does not automatically rise to the level of wilful disobedience. By distinguishing between intentional defiance and inadvertent oversight, the Court has ensured that penal consequences under Order XXXIX Rule 2A CPC are invoked only in cases where there is clear evidence of deliberate disregard for judicial authority.
At the same time, the ruling firmly reiterates a foundational principle of the legal system—court orders are binding and must be complied with in their entirety. Parties cannot selectively determine which directions are important or postpone compliance based on their own assessment of relevance. Even procedural directions, such as filing financial disclosures, carry equal weight and must be adhered to with diligence and discipline.
The imposition of costs and the direction to tender an apology underscore the Court’s message that while leniency may be shown in cases of genuine oversight, non-compliance cannot be treated casually or dismissively. The sanctity of judicial orders is central to the administration of justice, and any conduct that undermines this sanctity will attract consequences.
Ultimately, the decision serves as a clear reminder to businesses and litigants alike that in commercial disputes, compliance is not merely a procedural formality—it is a substantive obligation. It must be timely, complete, and carried out in good faith, ensuring that the authority of the Court is respected and the integrity of the judicial process is preserved.
Frequently Asked Questions (FAQs)
Q1. What was the main issue in PepsiCo v. Parle Agro? 
Ans. The case concerned whether Parle Agro had violated a prior injunction order restricting the use of the tagline “For The Bold” and failed to comply with related court directions.
Q2. What is Order XXXIX Rule 2A CPC? 
Ans. It is a provision under the Code of Civil Procedure that allows courts to take action against a party for disobeying or breaching an injunction order, including imposing penalties.
Q3. What does “wilful disobedience” mean in law? 
Ans. Wilful disobedience refers to a deliberate and intentional violation of a court order. Mere negligence or oversight does not usually qualify.
Q4. Did the Court find Parle Agro guilty of wilful disobedience? 
Ans. No. The Court held that the continued presence of certain advertisements was due to inadvertence and not deliberate intent, and therefore did not amount to wilful disobedience.
Q5. Why were the social media posts not treated as a violation? 
Ans. The Court noted that the posts were old (from 2022) and remained due to oversight. Since they were removed once identified, the conduct was not considered intentional.
Q6. What was the issue regarding sales revenue disclosure? 
Ans. Parle Agro failed to file sales revenue data every two months, as directed by the Court, for over two years.
Q7. How did the Court view the non-filing of sales data? 
Ans. The Court held this to be a serious and clear violation, even if not wilful, because the direction was explicit and remained unfulfilled.
Q8. What penalty was imposed by the Court? 
Ans. The Court imposed a cost of Rs.10,00,000 on the defendant and directed the filing of an unconditional apology.
Q9. What principle did the Court emphasise regarding compliance? 
Ans. The Court stressed that all directions of a court must be followed, regardless of whether a party considers them important or relevant.
Q10. What is the significance of this judgment? 
Ans. The judgment clarifies the threshold for wilful disobedience, reinforces the importance of compliance with court orders, and highlights challenges in enforcing orders in the digital and commercial context.

In commercial litigation, interim injunctions are often the most critical stage of a dispute. They aim to preserve rights and prevent ongoing harm until the final adjudication. However, the real challenge arises not in granting such orders, but in ensuring their effective enforcement.

The Delhi High Court’s decision in Pepsico Inc. & Anr. v. Parle Agro Pvt. Ltd. (2026) provides important clarity on this issue. The case revolves around alleged violations of an earlier injunction concerning the use of the tagline “For The Bold” and raises a fundamental question:

When does non-compliance with a court order become “wilful disobedience” warranting penal consequences?

The judgment offers a nuanced answer by distinguishing between deliberate defiance and inadvertent lapse, thereby shaping the contours of enforcement under Order XXXIX Rule 2A of the Code of Civil Procedure, 1908 (CPC).

Background of the Dispute

The dispute originated from a trademark and passing off claim filed by PepsiCo Inc., alleging that Parle Agro Pvt. Ltd. had infringed its registered tagline “For The Bold.”

In the earlier stage of the litigation, the Delhi High Court, through its order dated 18 September 2023, granted limited injunctive relief. Importantly, the Court did not impose a blanket prohibition on the use of the tagline. Instead, it crafted a balanced and conditional order, allowing certain uses while restricting others.

The directions included:

Restricting modification of product labels without prior approval
Prohibiting the use of “For The Bold” as the dominant element in advertising campaigns
Directing the removal of specific advertisements on social media platforms
Requiring the defendant to periodically disclose sales revenue data

This calibrated approach reflected the Court’s attempt to balance trademark rights with commercial freedom.

Trigger for the Present Proceedings

The present proceedings were initiated when PepsiCo approached the Delhi High Court by filing an application under Order XXXIX Rule 2A of the Code of Civil Procedure, 1908, alleging that Parle Agro had failed to comply with the earlier interim injunction order dated 18 September 2023. This provision empowers the Court to take action in cases where a party is accused of disobeying or breaching an injunction, and may even lead to penal consequences such as attachment of property or civil imprisonment.

PepsiCo’s application was not based on a single isolated instance but on what it described as a pattern of continued non-compliance, which, according to the plaintiff, undermined both its trademark rights and the authority of the Court. The allegations were structured around two primary grounds:

Continued Display of Advertisements

PepsiCo alleged that despite the Court’s clear direction to take down advertisements featuring the tagline “For The Bold”, certain promotional content remained accessible on the defendant’s social media platforms, particularly:

X (formerly Twitter)
Instagram

The plaintiff emphasised that compliance with an injunction is not partial but must be complete and effective. Therefore, the mere existence of even a few posts containing the prohibited tagline indicated that the defendant had not fully adhered to the Court’s directions. It was further argued that in the digital age, where content can be accessed and shared instantly, failure to remove such posts could result in continued commercial advantage and consumer confusion, thereby defeating the purpose of the injunction.F

Non-Compliance with Financial Disclosure

The second and more serious allegation related to the defendant’s failure to comply with the Court’s direction to periodically file sales revenue certificates associated with the use of the impugned tagline.

The earlier order had specifically required Parle Agro to:

Submit sales revenue data every two months
Cover the period from the commencement of the use of the label containing “For The Bold”

PepsiCo contended that this requirement was not merely procedural but served an important purpose, namely:

To monitor the extent of commercial benefit derived from the use of the tagline
To assist the Court in determining damages or profits at a later stage

PepsiCo characterised this conduct as:

Continuous – extending over a significant period
Unexplained – lacking any reasonable justification
Contemptuous – showing indifference to the authority of the Court

Defendant’s Response

Parle Agro contested the allegations in their entirety and sought to present the issue not as one of intentional or wilful violation, but as a case of inadvertent and unintentional non-compliance. The defence was structured to demonstrate that the defendant had acted in good faith, had substantially complied with the Court’s earlier directions, and that any lapse was minor, accidental, and promptly corrected once brought to its notice.

Its response rested on the following key arguments:

No Fresh Violation

At the outset, the defendant emphasised that it had fully respected the spirit of the Court’s injunction by refraining from issuing any new advertisements using the tagline “For The Bold” after the order dated 18 September 2023.

It was argued that:

The injunction did not impose a blanket prohibition on all past usage, but was primarily directed at preventing continued or future misuse.
The defendant had not launched any fresh marketing campaign or promotional material in violation of the order.

Legacy Content on Social Media

With respect to the advertisements cited by the plaintiff, the defendant clarified that these were old social media posts dating back to 2022, i.e., prior to the passing of the injunction order.

The continued presence of these posts was attributed to practical and operational challenges, including:

Oversight – Given the large volume of content managed by the company’s marketing teams, a few posts were inadvertently missed during the removal process.
Volume of Digital Content – The defendant maintained multiple social media accounts with hundreds of posts and campaigns, making complete and immediate tracking of every instance difficult.
Technical and Logistical Difficulties – Locating and removing older or archived posts across platforms can involve technical limitations and delays, especially where content is spread across different accounts or formats.

Immediate Rectification

A key plank of the defence was the assertion of prompt corrective action. The defendant submitted that:

As soon as it became aware of the existence of the remaining posts—through the present application—it immediately removed or took down the content.
This conduct demonstrated its bona fide intention to comply with the Court’s directions.

Revenue Disclosure Not Urgent

On the issue of non-filing of sales revenue data, the defendant sought to minimise the significance of the alleged breach.

It argued that:

The requirement to file sales revenue certificates every two months was primarily relevant at the stage of determining damages or profits, which would arise only during trial.
At the current stage of proceedings—where issues were yet to be framed and evidence had not commenced—the absence of such data did not cause any immediate or tangible prejudice to the plaintiff.

The defendant further contended that:

The delay in filing the data was not wilful or deliberate, but rather a procedural lapse.
The necessary financial records were maintained and available, and could be produced when required by the Court.

Issues Before the Court

The Court narrowed the controversy into two distinct questions:

Whether the continued presence of advertisements amounted to wilful disobedience
Whether failure to file sales revenue data constituted serious non-compliance

At the heart of both issues lay the interpretation of “wilful disobedience” under Order XXXIX Rule 2A CPC.

Court’s Analysis

Non-Removal of Advertisements

The Court first examined the issue of the allegedly infringing advertisements.

It noted certain inconsistencies in the defendant’s affidavits, particularly regarding whether the posts were on its own accounts or third-party platforms.

However, the Court did not treat these inconsistencies as decisive. Instead, it focused on the intent behind the conduct.

Key observations included:

The posts were dated 2022, prior to the injunction
The defendant had taken down most offending content
Only a small number of posts remained

The Court accepted the explanation that the omission was due to oversight rather than deliberate defiance.

Finding

The Court held that:

The conduct did not amount to wilful disobedience
Penal action under Order XXXIX Rule 2A CPC was not warranted

Failure to File Sales Revenue Data

On this issue, the Court adopted a markedly stricter approach.

The direction to file revenue data was:

Clear
Specific
Time-bound

Despite this, the defendant had failed to comply for over two and a half years.

The Court rejected the defendant’s argument that:

The data was not immediately relevant
Delay caused no prejudice

Instead, it emphasised a fundamental principle:

Parties cannot decide the importance of a court’s direction—compliance is mandatory.

The Court observed that such non-compliance undermines:

The authority of the Court
The integrity of judicial proceedings

The Legal Standard: What is “Wilful Disobedience”?

A central contribution of the judgment is its clarification of the term “wilful disobedience.”

The Court held that:

Wilful disobedience requires intentional and conscious violation
Mere negligence or oversight is insufficient
The standard is high because the consequences are penal in nature

This interpretation aligns with the Supreme Court’s view that proceedings under Order XXXIX Rule 2A are quasi-criminal, and therefore require strict proof.

Relief and Directions

While the Court declined to impose penal consequences for the advertisement issue, it took serious note of the financial disclosure violation.

The Court ordered:

Imposition of Costs: A cost of Rs.10,00,000 was imposed on the defendant, payable to the “Bharat Ke Veer” fund.
Apology Requirement: The deponent of the affidavits was directed to tender an unconditional apology.
Emphasis on Compliance: The Court reiterated that its orders must be followed in both letter and spirit.

Significance of the Judgment

Clear Threshold for Wilful Disobedience

The judgment draws a clear line between:

Deliberate violation (punishable)
Inadvertent lapse (not punishable)

This provides much-needed clarity in enforcement proceedings.

Strengthening Judicial Authority

By imposing costs despite the absence of wilfulness, the Court reinforced that:

Non-compliance has consequences
Judicial orders must be taken seriously

Digital Compliance Challenges

The case highlights practical challenges in ensuring compliance in the digital ecosystem, where:

Content persists across platforms
Legacy posts may remain unnoticed

Accountability in Commercial Litigation

The decision underscores that large corporations must maintain robust compliance mechanisms, especially when subject to court orders.

Broader Implications

The judgment has implications beyond the immediate dispute:

It guides how courts will approach social media compliance
It sets standards for corporate accountability
It reinforces the importance of procedural discipline in litigation

Conclusion

The Delhi High Court’s ruling in Pepsico Inc. v. Parle Agro Pvt. Ltd. stands as a carefully balanced and thoughtfully reasoned decision that reconciles two competing considerations—fairness to litigants and strict enforcement of judicial orders. The Court consciously avoided adopting a rigid or overly punitive approach, and instead undertook a nuanced examination of the nature of the alleged non-compliance.

In doing so, the judgment recognises an important practical reality of modern commercial litigation: not every lapse in compliance necessarily amounts to a legal violation, and even where a violation is established, it does not automatically rise to the level of wilful disobedience. By distinguishing between intentional defiance and inadvertent oversight, the Court has ensured that penal consequences under Order XXXIX Rule 2A CPC are invoked only in cases where there is clear evidence of deliberate disregard for judicial authority.

At the same time, the ruling firmly reiterates a foundational principle of the legal system—court orders are binding and must be complied with in their entirety. Parties cannot selectively determine which directions are important or postpone compliance based on their own assessment of relevance. Even procedural directions, such as filing financial disclosures, carry equal weight and must be adhered to with diligence and discipline.

The imposition of costs and the direction to tender an apology underscore the Court’s message that while leniency may be shown in cases of genuine oversight, non-compliance cannot be treated casually or dismissively. The sanctity of judicial orders is central to the administration of justice, and any conduct that undermines this sanctity will attract consequences.

Ultimately, the decision serves as a clear reminder to businesses and litigants alike that in commercial disputes, compliance is not merely a procedural formality—it is a substantive obligation. It must be timely, complete, and carried out in good faith, ensuring that the authority of the Court is respected and the integrity of the judicial process is preserved.

Frequently Asked Questions (FAQs)

Q1. What was the main issue in PepsiCo v. Parle Agro?

Ans. The case concerned whether Parle Agro had violated a prior injunction order restricting the use of the tagline “For The Bold” and failed to comply with related court directions.

Q2. What is Order XXXIX Rule 2A CPC?

Ans. It is a provision under the Code of Civil Procedure that allows courts to take action against a party for disobeying or breaching an injunction order, including imposing penalties.

Q3. What does “wilful disobedience” mean in law?

Ans. Wilful disobedience refers to a deliberate and intentional violation of a court order. Mere negligence or oversight does not usually qualify.

Q4. Did the Court find Parle Agro guilty of wilful disobedience?

Ans. No. The Court held that the continued presence of certain advertisements was due to inadvertence and not deliberate intent, and therefore did not amount to wilful disobedience.

Q5. Why were the social media posts not treated as a violation?

Ans. The Court noted that the posts were old (from 2022) and remained due to oversight. Since they were removed once identified, the conduct was not considered intentional.

Q6. What was the issue regarding sales revenue disclosure?

Ans. Parle Agro failed to file sales revenue data every two months, as directed by the Court, for over two years.

Q7. How did the Court view the non-filing of sales data?

Ans. The Court held this to be a serious and clear violation, even if not wilful, because the direction was explicit and remained unfulfilled.

Q8. What penalty was imposed by the Court?

Ans. The Court imposed a cost of Rs.10,00,000 on the defendant and directed the filing of an unconditional apology.

Q9. What principle did the Court emphasise regarding compliance?

Ans. The Court stressed that all directions of a court must be followed, regardless of whether a party considers them important or relevant.

Q10. What is the significance of this judgment?

Ans. The judgment clarifies the threshold for wilful disobedience, reinforces the importance of compliance with court orders, and highlights challenges in enforcing orders in the digital and commercial context.