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29. The learned Amicus further submits that the orders relied upon by the petitioner, including the orders passed in Crl.Misc.(Main) Nos. 31/1984 and 1854/1986, are undertaking or declaration made in the course of criminal proceedings, which cannot be equated with enforceable civil directions. It is further stated that even assuming such undertakings were given, breach of an undertaking in a separate proceeding, decades later, cannot be treated as continuing contempt, unless the same relates to a clear and subsisting judicial decision.