M/S. Maruti Ltd. (In Liqn.), Chandigarh ... vs M/S. Pan India Plastic Pvt. Ltd. on 20 November, 1992
The Calcutta High Court in I.K. Merchants v. Indra Prakash Karnani, AIR 1973 Calcutta 306, observed that onus is very heavy on the decree-holder who must satisfy the Court that proviso to S. 51(c) is attracted before a judgment-debtor is sent to prison.