As per case facts, this Contempt Petition was filed by the Petitioner for alleged violation of an interim status quo order dated 07.03.2025 passed in W.P.(C) 2902/2025 concerning the immovable ...
CONT.CAS(C) 685/2025 & Connected Matters Page 1 of 31
$~J
* IN THE HIGH COURT OF DELHI AT NEW DELHI
% Judgment pronounced on: 02.02.2026
+ CONT.CAS(C) 685/2025
SATYA PRAKASH RAVIDAS .....Petitioner
versus
ALAKH NIRANJAN PRASAD SINGHNA & ORS. .....Respondents
+ W.P.(C) 13723/2025
SATYA PRAKASH RAVIDAS .....Petitioner
versus
THE ADM DISTRICT SOUTH & ORS. .....Respondents
+ W.P.(C) 15987/2025
SATYA PRAKASH RAVIDAS .....Petitioner
versus
THE REGISTRAR OF SOCIETIES & ANR. .....Respondents
+ W.P.(C) 16305/2025, CM APPL. 66703/2025, CM APPL.
68682/2025 & CM APPL. 70557/2025
SATYA PRAKASH RAVIDAS .....Petitioner
versus
UNION OF INDIA & ORS. .....Respondents
+ W.P.(C) 2902/2025, CM APPL. 19993/2025, CM APPL.
27880/2025, CM APPL. 34624/2025 & CM APPL. 38858/2025
SATYA PRAKASH RAVIDAS .....Petitioner
versus
SDM HQ REGISTRAR OF SOCIETIES & ANR. .....Respondents
Presence: Mr. Satya Prakash Ravidas, Petitioner in person in
CONT.CAS(C) 685/2025, W.P.(C) 13723/2025, W.P.(C)
15987/2025, W.P.(C) 16305/2025 & W.P.(C) 2902/2025.
CONT.CAS(C) 685/2025 & Connected Matters Page 2 of 31
Mr. Jayant Bhushan, Sr. Advocate along with Mr. Anil Dutt,
Mr. Yogit Mehra, Mr. Paras Choudhary, Mr. Amartya
Bhushan, Ms. Lavi Agarwal, Advocates for Raj Vidya Kender
in CONT.CAS(C) 685/2025, W.P.(C) 13723/2025, W.P.(C)
15987/2025, W.P.(C) 16305/2025 & W.P.(C) 2902/2025.
Mr. Ashish K. Dixit, CGSC along with Mr. Umar Hashmi,
Mr. Harshit Chitransh and Ms. Iqra Sheikh, Advocates for R-1
to R-5.
Mr. Dhruv Rohatgi, Panel Counsel (GNCTD) along with Mrs.
Chandrika Sachdev and Mr. Dhruv Kumar, Advocates for
GNCTD in W.P.(C) 16305/2025.
Mr. Dhananjaya Mishra, Mr. Navneet Dogra and Mr. Amritesh
Mohanty, Advocates for R-1 in W.P.(C) 2902/2025.
CORAM:
HON'BLE MR. JUSTICE SACHIN DATTA
JUDGMENT
W.P.(C) 13723/2025, W.P.(C) 15987/2025, W.P.(C) 16305/2025 and
W.P.(C) 2902/2025
1. Multiple writ petitions have been filed by the petitioner concerning
the same society, i.e., Raj Vidya Kender (RVK). Having regard to the
overlapping nature of the causes of action and the commonality of issues
raised, it is considered appropriate to adjudicate all these petitions together.
2. The petitioner has approached this Court asserting his association
with the affairs of RVK, a society registered under the Societies Registration
Act, 1860, and formerly known as the Divine United Organisation (DUO).
The petitioner has invoked the writ jurisdiction of this Court aggrieved with
the current management and functioning of the society. According to the
petitioner, there exists an alleged error in the bylaws of RVK, whereby the
CONT.CAS(C) 685/2025 & Connected Matters Page 3 of 31
name of a fictitious individual, “Param Hans Sad Guru Dev Sri Sant Ji
Maharaj,” has been inserted in place of the real and living individual, Mr.
Prem Rawat.
3. It is further submitted that paragraph 3(a) of the bylaws of RVK
describes the principal objective of the society as the propagation of the
knowledge of “Param Hans Sadgurudev Shri Sant Ji Maharaj,” who,
according to the petitioner, is a non-existent person. This alleged error has,
in the petitioner’s view, enabled unelected individuals to seize control of the
society and exploit it for their personal benefit.
4. The petitioner additionally contends that sub-paragraph 4(d) has been
misused to suppress dissent and to insulate alleged offenders from
accountability. He claims that key positions within RVK have been usurped
by shareholders and employees of certain private entities, including those
associated with one Mr. Deepak Raj Bhandari. It is contended that Mr.
Deepak Raj Bhandari, a Nepalese national, who exercises unlawful control
over RVK has committed a financial fraud of ₹550.30 crores in relation to
RVK.
5. It is also the petitioner’s allegation that the purported unelected
governing body of RVK fabricated an authorization letter dated 16.04.2019
to initiate false litigation (CS (OS) 470/2019) against him. He further
highlights that no balance sheets, election records, or statutory filings of
RVK have been submitted before the Registrar of Societies since 2003.
6. The case of the petitioner is that RVK has remained a defunct society
since 2003, with no lawful elections to its governing body for more than
twenty-two years. The petitioner seeks to fasten admission/s by the Registrar
of Societies, on the basis of certain communications, dated 20.11.2023,
CONT.CAS(C) 685/2025 & Connected Matters Page 4 of 31
27.09.2023, and 27.05.2024. It is emphasised that the Registrar has the
authority to directly intervene and conduct an election for a society if the
existing election process is deemed invalid or improperly conducted. It is
submitted that the Registrar is vested with powers under Sections 12, 12A,
13, 14, and 19 of the Act to regulate, call for information, and conduct
enquiries into the affairs of societies.
7. It is submitted that the prolonged absence of elections and functioning
governance renders all subsequent activities of RVK void and illegal. It is
pointed that the unelected and unauthorized persons of RVK, have
unlawfully sold the Ashram “Prem Bhawan Raj Vidya Kendra, Near Gaya
Gumti, Patna. It is pointed that from 1987 onwards, the respondents, in
collusion with private individuals are transferring and vesting DUO’s
immovable and movable properties into various private companies, trusts,
and entities without the sanction of the General Body or compliance with
statutory provisions.
8. Another grievance of the petitioner is that the present managing body
of RVK is conducting public events, collecting donations, and issuing
communications in the name of Shri Prem Rawat, who is not recognized
anywhere in the registered Memorandum of Association or bylaws of RVK.
It is also emphasised that under the guise of a charitable society unelected
and unauthorized persons of RVK are collecting funds without
authorization.
9. In W.P. (C) No. 13723 of 2025 the petitioner has also challenged a
notice dated 30.07.2025 issued by the Fist Appellate Authority, intimating
that a hearing was scheduled on 21.08.2025. Notice dated 30.07.2025 is
reproduced as under –
CONT.CAS(C) 685/2025 & Connected Matters Page 5 of 31
10. However, it is submitted that the said notice was dispatched only at
17:01 hours on 21.08.2025, i.e., after the date and time fixed for the
petitioner’s appearance, and was delivered to him only on 26.08.2025, as
reflected in the India Post tracking records (ED5356781671N). It is
submitted that this sequence of events clearly evidences mala fides,
deliberate administrative delay, and denial of a reasonable opportunity of
hearing, thereby vitiating the entire proceedings.
11. It is submitted that prior to this, on 26.04.2025, the Petitioner had
filed an RTI application (ID No. 175-TRTI/2025) seeking information
regarding one “Udayanand,” who is purportedly shown as the Vice-
CONT.CAS(C) 685/2025 & Connected Matters Page 6 of 31
President of RVK. It is submitted that the said individual, however, is a
fictitious person with no known identity, parentage, or existence. It is
submitted that to the said RTI application the petitioner received vague and
evasive replies dated 02.05.2025 and 18.06.2025, failing to address the core
issue of the fictitious nature of “Udayanand,” which raises grave concerns of
fraud and manipulation within RVK’s governance structure.
12. Feeling aggrieved with the aforesaid, the petitioner has filed the
present batch of petitions.
13. In W.P. (C) no. 2902 of 2025, the petitioner has prayed as under –
“a) Direct the Respondent No.1 to perform his statutory duty by
recording the Petitioner's name as *Caretaker* of *Respondent No.2.* to
safeguard its assets and interests. I further request that this arrangement
remain in place until a General Body meeting is convened to submit the
balance sheet for the last 10 years.
b) Cancel the sale deed of the Ashram Prem Bhawan Patna executed on
30.11.2024 with immediate effect.”
14. In W.P. (C) no. 2902 of 2025, the petitioner has also filed an amended
writ petition, wherein the petitioner has prayed as under –
15. In W.P. (C) no. 16304 of 2025, the petitioner has made the following
prayers –
“(a) Issue a Writ of Mandamus directing the Respondent authorities,
namely the Registrar of Societies (NCT of Delhi) and Station House
Officers of P.S. Maidan Garhi (New Delhi) and P.S. Genome Valley
(Telangana), to verify the legal status, governing body, and authenticity
of the society "Raj Vidya Kender" (formerly "Divine United
Organization") before granting or permitting any public events in its
name.
CONT.CAS(C) 685/2025 & Connected Matters Page 7 of 31
(b) Issue a Writ of Prohibition or interim stay on the public events
announced as the "125th Anniversary of Hans Jayanti" scheduled on 08-
09.11.2025 at Raj Vidya Kender, Shahurpur, New Delhi, and 26.11.2025
at Raj Vidya Kender (South), Turkapally, Telangana, until:
a valid General Body Meeting is duly convened, and
lawful amendment is made replacing the fictitious name "Param Hans
Sadgurudev Shri Sant Ji Maharaj" with "Shri Prem Rawat" in the
Memorandum of Association.
(c) Direct the Registrar of Societies to conduct an inquiry under Sections
12 and 12A of the Societies Registration Act, 1860, into the legality of the
2003 amendments and the alleged unauthorized collection of funds in the
name of Shri Prem Rawat.”
16. In W.P. (C) NO. 15987 of 2025, the following prayers have been
made –
“(a) Issue a writ, order, or direction in the nature of mandamus directing
the Respondents to produce before this Hon'ble Court the resolution(s)
passed in the Governing Body meetings of Raj Vidya Kender (RVK),
together with all records relating to the erstwhile society Divine United
Organisation (DUO) and its subsequent change of name to RVK on
07.07.2003, including full particulars of all immovable and movable
properties of DUO that were allegedly transferred, vested, or otherwise
dealt with under RVK.
(b). In the alternative, if the Respondents fail, neglect, or refuse to
produce such records, this Hon'ble Court may be pleased to direct
Respondent No. 1 (Registrar of Societies, NCT of Delhi) to conduct a
statutory enquiry under the Societies Registration Act, 1860 into the
affairs of Respondent No. 2 (RVK), and to take consequential action,
including cancellation of registration, if violations of the Act are
established.”
17. In W.P. (C) NO. 13723 of 2025, the petitioner has prayed as under –
“a. Issue a writ of 'Mandamus', or any other appropriate writ, order, or
direction, commanding Respondent No.3 to convene an urgent General
Body Meeting in the presence of the owner of the intellectual property, o
Mr. Prem Rawat" which has not been held for the past 22 years, for
considering pending court cases and appointment of legal counsel to
represent and engagement of advocate to represent Respondent Nop.3.
CONT.CAS(C) 685/2025 & Connected Matters Page 8 of 31
b. Issue a writ of 'Certiorari', or any other appropriate writ, order, or
direction, quashing the notice dated 30.07.2025 issued by Respondent
No.1 along with all consequential proceedings.”
18. Further the petitioner has filed a common synopsis in the present
petitions wherein the following submissions have been made by the
petitioner –
i. There exists a complete breakdown of legal governance in the Divine
Light Universal Organisation (DUO), now projected as Raj Vidya
Kender (RVK). It is submitted that based on the official records
produced by the Registrar of Societies on 12.11.2025, it is
conclusively established that the original bylaws of DUO
unequivocally designate Shri Prem Rawat as the Patron for life.
Under the bylaws, only the Patron is empowered to appoint an ad-
hoc committee, authorize the Governing Body, or approve any
amendment. No person or body is competent to remove or
supersede the Patron. It is averred that this single admitted fact
fundamentally invalidates the claims of the private individuals who
have unlawfully taken over DUO/RVK and have acted as “office
bearers” without any lawful authority.
ii. The Registrar of Societies file, produced before this Court for
inspection, demonstrates that DUO has not held a single General
Body Meeting for decades and that no resolutions, elections,
audited accounts, or filings exist on record. The file does not
contain (i) any General Body resolution authorizing an election;
(ii) any record of lawful proceedings under the Societies
Registration Act; or (iii) any approval of amendments or name
CONT.CAS(C) 685/2025 & Connected Matters Page 9 of 31
change by the Patron. Consequently, every action undertaken in
the name of DUO or RVK, including the purported name change,
constitution of any governing body, dealing with society assets,
and transactions relating to Patna Ashram, is void ab initio, non est
in law, and constitutes fraud upon the statute.
iii. It is emphasised that the alleged change of name from DUO to “Raj
Vidya Kender” on 04.07.2023 is a glaring instance of illegality. It
is submitted that the mandatory conditions under the Societies
Registration Act and the DUO bylaws, requiring a properly
convened General Body Meeting and Patron’s approval, have
never been satisfied. Accordingly, the purported name change is
absolutely void, confers no legal validity, and cannot vest any
authority in those claiming to represent RVK.
iv. It is pointed that after the unauthorized takeover, the private
individuals unlawfully removed the Patron from his rightful
position and embarked upon a systematic process of diverting
DUO’s charitable assets. They created private companies,
transferred DUO properties into such entities, and misappropriated
substantial funds.
v. It is further submitted that the purported sale of the Patna Ashram is
void ab initio. DUO/RVK never had a validly constituted
Governing Body, nor was there any resolution, authorization,
power of attorney, or approval from the Patron permitting sale of
any charitable property. The alleged transfer is wholly illegal, ultra
CONT.CAS(C) 685/2025 & Connected Matters Page 10 of 31
vires the bylaws, contrary to statute, and incapable of conferring
rights upon any purchaser irrespective of the alleged consideration.
vi. The petitioner further submitted that DUO’s charitable properties,
including the Patna Ashram and other assets across India, were
created from public donations for religious, spiritual, educational,
and public-benefit purposes. These assets cannot be treated as the
private property of individuals. Misappropriation or alienation of
such property is a matter of public trust, and this Court, in exercise
of its jurisdiction under Article 226, is empowered and obligated to
preserve the status quo ante to prevent irreversible harm to
charitable property.
19. In the said common synopsis, the petitioner has further prayed as
under –
20. On the other hand, while controverting to the aforesaid contentions of
the petitioner RVK has submitted as under -
CONT.CAS(C) 685/2025 & Connected Matters Page 11 of 31
i. In 1977, a society named Divine United Organisation (DUO), applied
for registration under the Societies Registration Act, 1860. The
application, submitted on 20.05.1977, enclosed the proposed
Memorandum of Association (MOA) and Rules and Regulations.
ii. Under the original Rules and Regulations, Param Hans Sadguru Dev
Shri Sant Ji Maharaj @ Balyogeshwar @ Shri Prem Pal Singh Rawat
(popularly known as Shri Guru Maharaj Ji) was designated as ‘Patron’
and was to hold the position for life. The society recognized three
categories of membership, Patron, Life Member, and Ordinary
Member.
iii. Upon objections by the Registrar of Societies, DUO submitted an
amended MOA and Rules on 26.09.1977. The amendments removed
the ‘Patron’ category, limited membership to Life and Ordinary
Members, and altered the registered office. DUO was thereafter
registered on 31.10.1977, with its aims and objects remaining
substantially unchanged.
iv. In 2003, pursuant to majority approval of the Governing Body, DUO
amended its MOA and changed its name to Raj Vidya Kender (RVK).
It is submitted that the amendments followed four special general
body meetings held on 02.08.2002, 08.09.2002, 04.10.2002 and
10.12.2002.
v. It also emphasised that the Registrar of Societies has acknowledged
that RVK regularly filed its Annual Governing Body lists under
Section 4 of the Act at least until 2019. It is submitted that filings
CONT.CAS(C) 685/2025 & Connected Matters Page 12 of 31
have continued up to 2025 and that elections are conducted every five
years, the latest having taken place in 2024.
vi. The principal objective of RVK remains the propagation of the
teachings of Mr. Prem Rawat, an internationally known speaker and
author. References to “Param Hans Sadguru Dev Shri Sant Ji
Maharaj” in the Rules and Regulations pertain to Mr. Prem Rawat.
vii. It is also pointed that a separate entity, Raj Vidya Kender
(South), is a registered trust in Chennai. It is distinct from RVK
(Delhi) and has no overlapping trustees or governing body members.
viii. It is further submitted that due to the petition’s involvement in
illegal and anti-social activities, the Petitioner was blacklisted from
entering RVK premises from 14.01.2014. The case of the RVK is that
the petitioner has no locus to file petitions concerning RVK, as he is
neither a member nor affiliated with the society.
ix. It is submitted that RVK has filed a defamation suit (CS(OS)
470/2019) against the petitioner. An interim stay order was passed on
19.07.2023 and subsequently made absolute on 10.04.2024. The suit
remains pending.
x. The petitioner has thereafter filed multiple writ petitions and
applications against RVK on overlapping grounds. It is submitted that
a recent habeas corpus petition (W.P.(Crl.) 2399/2025) was dismissed
by the Division Bench on 09.09.2025.
CONT.CAS(C) 685/2025 & Connected Matters Page 13 of 31
xi. It is averred that Courts have repeatedly noted that the petitioner files
frivolous and repetitive petitions without disclosure of prior
proceedings.
xii. It is further submitted that Section 13 of the Societies
Registration Act, 1860 bars the writ jurisdiction of this Court over
private disputes concerning management of a registered society, for
which civil remedy is prescribed.
xiii. It is contended that the petitioner has alleged that Mr.
Udayanand is a fictitious person. It is submitted that this is factually
incorrect. Mr. Udayanand is currently the Vice-President of the
Society. It is further submitted that the petitioner has not disclosed the
fact that a similar plea has been dismissed by a Coordinate Bench of
this Court in W.P.(Crl.) 2714/2025 vide order dated 28.08.2025.
xiv. It is also submitted that the petitioner alleges that Mr. Deepak
Raj Bhandari has siphoned crores of money from the Society. It is
submitted that an identical plea was raised in IA no. 7752 of 2025
filed in CS (OS) 470/2019 which was dismissed vide order dated
25.03.2025 and the petitioner was warned from filing such frivolous
application. This fact not been disclosed
xv. Lastly it is the case of RVK that the Petitioner is a habitual litigant
who repeatedly abuses judicial process, as recognized in several
orders. In order to substantiate its case reliance has been placed on the
judgment of the Supreme Court in Pandurang Vithal Kevne v. BSNL
& Anr., 2024 SCC OnLine SC 4108.
CONT.CAS(C) 685/2025 & Connected Matters Page 14 of 31
21. During the course of arguments, the Registrar of society has
submitted as under -
i. It is submitted that the reliefs sought pertain to the internal
management and private disputes concerning a society registered
under the Societies Registration Act, 1860 (“the Act”). Matters
relating to the governance, control, and administration of a
registered society are essentially private law disputes, for which
appropriate civil remedies are available.
ii. It is submitted that the statutory framework under the Act is narrow
and circumscribed. Under Section 3 of the Act, the Registrar has a
function of registering a society upon filing of a memorandum of
association referable to Sections 1, 2, and 20 of the Act. Under
Section 4, the limited role of the Registrar is to receive the annual
list of the managing body of a registered society. Under Section
12A (as applicable to Delhi), when there is any change in name of
the Society after following the procedure prescribed in Section 12
of the Act, the proposition of change in name is required to be filed
with the Registrar for change in name. In terms of Section 12 (2),
the Registrar has to apply its mind as to whether the proposed
name is identical or similar to any other existing society.
iii. It is further emphasised that the facts relevant to the present case
indicate that the society in question was registered under the name
“Devine United Organisation” on 31.10.1977 under Section 3 of
the Act, and subsequently changed its name to “Raj Vidya
CONT.CAS(C) 685/2025 & Connected Matters Page 15 of 31
Kender” on 07.07.2003 in accordance with Sections 12 and 12A.
The last annual list of the governing body was filed on 30.01.2019.
iv. It is submitted that this Court has consistently held that the Registrar
of Societies does not possess supervisory, disciplinary, or
regulatory powers over the internal affairs of societies registered
under the Act. Reliance has been placed on order dated 12.04.2012
passed in Supreme Court Bar Association (Regd.) v. Registrar of
Societies & Ors., W.P.(C) 3260/2010, Dinesh Kumar v. Registrar
of Societies, 2011 SCC OnLine Del 2814, and Hua Seng Chew v.
Registrar of Societies and Firms, W.P.(C) 8604/2020.
v. It is submitted that registrar of societies is merely a registering
authority and has no jurisdiction to interfere in the management,
functioning, or internal affairs of a registered society. Any
grievance relating to administration, membership, meetings,
elections, or property of the society is required to be adjudicated
before the competent civil court.
ANALYSIS AND CONCLUSION
22. Having heard both the parties, this Court is of the view that the
grievance/s of the petitioner cannot be adjudicated in exercise of jurisdiction
under Article 226 of the Constitution of India.
23. It is a well-settled position of law that disputes relating to the internal
management of a society must be adjudicated before a competent civil court
and cannot be adjudicated in writ jurisdiction. In Dinesh Kumar & Anr. v.
The Registrar of Societies & Ors, 2011 SCC OnLine Del 2814, the Court
CONT.CAS(C) 685/2025 & Connected Matters Page 16 of 31
has categorically held as under –
“4. The counsel for the respondent No. 1 Registrar of Societies
appearing on advance notice states that the Registrar under the
Societies Registration Act has no power in the matter and is not in a
position to decide the inter se disputes between the Members and the
Management of the Society. It is stated that the Registrar is only a
registering authority and is not empowered to approve or disapprove
any amendment or to take any action with respect to any
irregularities.
5. The counsel for the petitioner has also not been able to show any
duty or obligation under the law upon the Registrar of Societies to
take any action and which it may be failing to perform or take.
Without the petitioners showing that there is any denial to perform
the obligation or duty required to be performed in law, no mandamus
can be claimed.
6. Besides the aspect of delay, which has not been satisfactorily
explained, I am also of the view that the writ petition qua the inter
se disputes of Members and the Management of the Society does
not lie. The earlier writ petition preferred for the same relief though
by others was also withdrawn with liberty to seek appropriate relief.
The rejection of the plaint in the suit preferred thereafter was as
barred by limitation. If the plaintiffs in the suit are aggrieved from
the said finding, they are to seek remedies against the said judgment
and cannot again maintain a writ petition. I may also notice that the
challenge to the amendment is inter alia on the ground that the
notice preceding the meeting in which the amendments were carried
out was defective. The said plea raises a disputed question of fact
which in any case cannot be adjudicated in writ jurisdiction.”
24. The petitioner has also raised objections concerning the functioning of
the Registrar of Societies and has asserted that the Registrar is vested with
authority under Sections 12, 12A, 13, 14, and 19 of the Societies
Registration Act, 1860 to regulate and conduct inquiries into the affairs of
registered societies.
25. At this juncture, it is relevant to note that in an earlier order dated
19.05.2025 passed in CM APPL.22817/2025 in W.P.(C) 2902/2025, the
CONT.CAS(C) 685/2025 & Connected Matters Page 17 of 31
submissions made on behalf of the Registrar of Societies were duly
recorded, wherein the Registrar categorically stated that there was nothing
amiss in the affairs of the concerned society. In view thereof, the interim
order dated 07.03.2025 was vacated. The relevant portion reads as under:
“9. Considering the aforesaid circumstances, particularly the
submission of learned counsel for the respondent no. 1 that there is
nothing amiss about the state of affairs of the concerned society, the
interim order dated 07.03.2025 is vacated.”
26. Further, the Registrar of Societies has taken a stand that it lacks
jurisdiction over the society’s internal functioning and that its statutory role
is confined to registration and maintaining basic records.
27. In order to deal with the contentions raised by the petitioner regarding
the scope and extent of powers of the Registrar of Societies, particularly the
assertion that the Registrar is empowered under Sections 12, 12A, 13, 14,
and 19 of the Societies Registration Act, 1860 to regulate and inquire into
the internal affairs of societies, this Court deems it appropriate to first
examine the relevant statutory provisions. The said provisions are
reproduced as under -
“12. Societies enabled to alter, extend, or abridge their purposes.—
Whenever it shall appear to the governing body of any society registered
under this Act, which has been established for any particular purpose or
purposes, that it is advisable to alter, extend, or abridge such purpose to
or for other purposes within the meaning of this Act, or to amalgamate
such society either wholly or partially with any other society, such
governing body may submit the proposition to the members of the society
in a written or printed report, and may convene a special meeting for the
consideration thereof according to the regulations of the society;
but no such proposition shall be carried into effect unless such report
shall have been delivered or sent by post to every member of the society
ten days previous to the special meeting convened by the governing body
for the consideration thereof, nor unless such proposition shall have been
agreed to by the votes of three-fifths of the members delivered in person
or by proxy, and confirmed by the votes of three-fifths of the members
CONT.CAS(C) 685/2025 & Connected Matters Page 18 of 31
present at a second special meeting convened by the governing body at
an interval of one month after the former meeting.
12-A. Registration of change of name.—(1) Where a proposition for
change of name has been agreed to and confirmed in the manner
prescribed by Section 12, a copy of the proposition so agreed to and
confirmed shall be forwarded to the Registrar for registering the change
of name. If the proposed name is identical with that by which any other
existing society has been registered, or in the opinion of the Registrar so
nearly resembles such name as to be likely to deceive the public or the
members of the either society, the Registrar shall refuse to register the
change of name.
(2) Save as provided in sub-section (1), the Registrar shall, if he is
satisfied that the provisions of this Act in respect of change of name have
been complied with, register the change of name and issue a certificate of
registration altered to meet the circumstances of the case. On the issue of
such a certificate the change of name shall be complete.
(3) The Registrar shall charge for any copy of a certificate issued under
sub-section (2), a fee of rupee one or such large fee and exceeding
rupees five as the State Government may from time to time, direct; and
all fees so paid shall form part of the Consolidated Fund of India.
13. Provision for dissolution of societies and adjustment of their
affairs.—Any number not less than three-fifths of the members of any
society may determine that it shall be dissolved, and thereupon it shall be
dissolved forthwith, or at the time then agreed upon, and all necessary
steps shall be taken for the disposal and settlement of the property of the
society, its claims and liabilities, according to the rules of the said
society applicable thereto, if any, and, if not, then as the governing body
shall find expedient, provided that, in the event of any dispute arising
among the said governing body or the members of the society, the
adjustment of its affairs shall be referred to the principal Court of
original civil jurisdiction of the district in which the chief building of the
society is situate; and the Court shall make such order in the matter as it
shall deem requisite:
Provided that no society shall be dissolved unless three-fifths of the
members shall have expressed a wish for such dissolution by their votes
delivered in person, or by proxy, at a general meeting convened for the
purpose:
Provided that [whenever any Government] is a member of, or a
contributor to, or otherwise interested, in any society registered under
CONT.CAS(C) 685/2025 & Connected Matters Page 19 of 31
this Act, such society shall not be dissolved [without the consent of the
Government of the State of registration].
14. Upon a dissolution no member to receive profit.—If upon the
dissolution of any society registered under this Act there shall remain
after the satisfaction of all its debts and liabilities any property
whatsoever, the same shall not be paid to or distributed among the
members of the said society or any of them, but shall be given to some
other society, to be determined by the votes of not less than three-fifths of
the members present personally or by proxy at the time of the dissolution,
or, in default thereof, by such Court as aforesaid:
Clause not to apply to Joint-stock Companies.—Provided, however, that
this clause shall not apply to any society which shall have been founded
or established by the contributions of shareholders in the nature of a
Joint-stock Company.
19. Inspection of documents. Certified copes.—Any person may inspect
all documents filed with the Registrar under this Act on payment of a fee
of one rupee for each inspection; and any person may require a copy or
extract of any document or any part of any document, to be certified by
the Registrar, on payment of two annas for every hundred words of such
copy or extract; and such certified copy shall be prima facie evidence of
the matters therein contained in all legal proceedings whatever.”
28. It is also relevant to advert to Sections 3 and 4 of the Societies
Registration Act, 1860, which are as under:-
“3. Registration and fees.—Upon such memorandum and certified copy
being filed, the Registrar shall certify under his hand that the society is
registered under this Act. There shall be paid to the Registrar for every
such registration a fee of fifty rupees, or such smaller fee as [the State
Government] may, from time to time, direct; and all fees so paid shall be
accounted for to [the State Government].
4. Annual list of managing body to be filed.—Once in every year, on or
before the fourteenth day succeeding the day on which, according to the
rules of the society, the annual general meeting of the society is held, or,
if the rules do not provide for an annual general meeting, in the month of
January, a list shall be filed with the Registrar of Joint-stock Companies,
of the names, addresses and occupations of the governors, council,
directors, committee, or other governing body then entrusted with the
management of the affairs of the society.”
29. A perusal of the above mentioned provisions makes it abundantly
CONT.CAS(C) 685/2025 & Connected Matters Page 20 of 31
clear that the Societies Registration Act, 1860 does not confer upon the
Registrar of Societies any supervisory, adjudicatory, or disciplinary
authority over the internal affairs of registered societies.
30. Under Section 3 of the Act, the limited function of the Registrar as
that of registering a society upon submission of its Memorandum of
Association, while Section 4 merely casts a statutory obligation upon the
concerned office-bearers to file an annual return before the Registrar of
Societies, setting out the names, addresses, and occupations of the
governors, council, directors, committee, or other governing body then
entrusted with the management of the affairs of the society.
31. In Supreme Court Bar Association (Regd.) v. Registrar of Societies
& Ors., 2012:DHC:2422, this Court has categorically observed as under -
“12. Section 4 of the Act casts a duty on the persons concerned to file
an annual return before the ROS containing the names, addresses
and occupation of the members of the Executive Committee. But the
law does not provide for any contingency- much less for the
suspension or dissolution of the society because of failure to comply
with Section 4. The conclusion drawn by the ROS, that if a return is
not filed in terms of Section 4 of the Act, the society is liable to be
suspended or dissolved, or that its existence becomes illegal is, to say
the least, outrageous and unfounded. The Act does not vest any
control or supervisory or disciplinary power or jurisdiction in the
ROS to take action against a society registered under the Act. The
disputes in relation to a society registered under the Act would,
necessarily, have to be taken before, and resolved by the Civil
Court. This is also evident from Sections 13 and 14 of the Act,
which provide for resolution of issues dealt with therein by the
Court.”
32. Further, the scope of interference by the Registrar under Sections 12
and 12A of the Act has also been conclusively settled. In Sunil Agarwal and
Ors. v. Govt. of NCT Of Delhi And Ors., 2024:DHC:6515, this Court has
made the following observation -
CONT.CAS(C) 685/2025 & Connected Matters Page 21 of 31
“13…….At the same time, the Registrar of Societies in their Counter
Affidavit have also explicitly acknowledged that it does not have
jurisdiction over internal affairs of a registered society and their role
is limited up to registration of a society. They have also categorically
confirmed that they can neither decide, doubt or dispute regarding the
election of a society nor interfere in the dispute between the members
of the society.
14. Thus, in light of the explicit stand taken by Registrar of Societies,
relating to its jurisdiction, we have to examine whether the Registrar’s
reliance on Section 12 of the Act to reject the amendments to the MoA
has a legal foundation. Section 12 of the Act reads as follows:
12. Societies enabled to alter, extend or abridge their
purposes.— Whenever it shall appear to the governing
body of any society registered under this Act, which has
been established for any particular purpose or purposes,
that it is advisable to alter, extend, or abridge such
purpose to or for other purposes within the meaning of
this Act, or to amalgamate such society either wholly or
partially with any other society, such governing body
may submit the proposition to the members of the society
in a written or printed report, and may convene a special
meeting for the consideration thereof according to the
regulations of the society; but no such proposition shall
be carried into effect unless such report shall have been
delivered or sent by post to every member of the society
ten days previous to the special meeting convened by the
governing body for the consideration thereof, nor unless
such proposition shall have been agreed to by the votes
of three-fifths of the members delivered in person or by
proxy, and confirmed by the votes of three-fifths of the
members present at a second special meeting convened
by the governing body at an interval of one month after
the former meeting.”
[Emphasis Supplied]
15. Elucidating on the scope of Section 12 of the Act, the Division
Bench of this Court in Dushyant Sharma v. Haryana Wrestling
Association & Ors, has observed that Section 12 of the Act enables a
society to alter or amend its objects and purpose and does not extend
to registering any amendment in Rules and Regulations of the society.
Additionally, in Supreme Court Bar Association v. B.D. Kaushik, 5 the
Supreme Court observed that rules relating to the exercise of the right
to vote and contest elections do not amount to altering, amending, or
CONT.CAS(C) 685/2025 & Connected Matters Page 22 of 31
changing the aims and objects of the society and can be implemented
without the consent of the Registrar, as provided in the Act.
16. In light of the above, it is clear that the Registrar of Societies
does not have supervisory powers over the affairs of the society and
we must now consider whether the Petitioner’s prayer can be granted.
17. In the opinion of the Court, Registrars’ reliance on Section 12 of
the Act is misplaced. The provision specifically addresses situations
where the governing body of a society seeks to alter, extend, or
abridge the society’s ‘purposes’—essentially a change in the
objectives or mission of the society. It is intended to regulate changes
that would affect the very character and goals of the society, requiring
a higher threshold of approval from the members to ensure that such
changes are genuinely in the society’s best interests. In contrast, the
matter before the Court pertains merely to a change in the
composition of the governing body members, amendment of MoA and
by-laws and not a change in the society’s core purposes. Respondent
No. 3 society was established with the purpose of establishing
educational institutions, and this purpose has remained the same.
Therefore, any amendments in the constitution of the governing body
would not trigger Section 12 of the Act.
18. Furthermore, the Registrar of Societies does not have the
authority under Section 12, or any other provision of the Act, to
intervene in the internal affairs of the society, such as the election or
appointment of governing body members, unless it involves a
statutory violation. The communication dated 02nd November, 2020,
issued by the Registrar, indicates that the Registrar has assumed the
role of an adjudicatory body and questioned the changes in the
governing body, which is beyond the scope of powers conferred on
them by the Act. Furthermore, a society is entitled to have its own
rules and regulations, which constitute a contract among its members.
Although these rules must be registered under the Act, they do not
acquire a statutory character, and the authority to amend, vary, or
rescind such rules rests with the general body of the society’s
members. The society’s internal governance, including changes in the
governing body, is governed by its own rules, subject to compliance
with the Act, but not under the purview of Section 12, which strictly
pertains to changes in the society’s purposes.
19. That apart, the contention of the Registrar of Societies that the
relevant documents pertaining to the amendment in the MoA and by-
laws were not provided, and therefore the communication dated 13th
June, 2018 could not be taken on record under Section 12 of the Act,
is thus not sustainable. There is no provision of law cited by the
CONT.CAS(C) 685/2025 & Connected Matters Page 23 of 31
Registrar to substantiate this contention. The Societies Registration
Act does not empower the Registrar to impose additional procedural
requirements beyond those prescribed by the Act itself. The
Registrar’s demand for such documentation appears to be an
overreach of authority, as there is no statutory basis for requiring
these specific documents to validate an amendment in the rules and
regulations of a society already registered under the Act. Therefore,
the Registrar’s insistence on such documentation is without legal
foundation and cannot sustain.
20. In light of the foregoing, the Registrar’s impugned actions are
ultra vires the Act. The controversy arising from the communication
dated 28th July, 2023, issued in response to an RTI application filed
by Mr. Sanjay Kumar Khemka, needs to be addressed. In this
communication, the Registrar of Societies disregarded the earlier
communication dated 13th June, 2018 and instead relied on previous
records to assert that the composition of the society’s governing body
remains unchanged. Given this inconsistency, the communication
dated 28th July, 2023 must be disregarded.
21. That said, it must be clarified that the observations made by this
court are only for the purpose of creating an interim arrangement, till
such time, the Civil Court in Civil Suit No. CS SCJ No. 313/24, 6 takes
a final view in the matter relating to the legality of the meeting dated
13th June, 2018. As can be noted from the prayers sought in the Civil
Suit preferred by the intervenors, the minutes dated 13th June, 2018
and the resolutions passed therein, have been impugned as void ab
initio and non est in law. The resolution of these issues falls squarely
within the jurisdiction of the Civil Court, which must adjudicate the
validity of the meeting and the decisions taken therein. The final
decision of the Civil Court will be binding on the Registrar of
Societies/Respondent No.2 and will determine the legitimacy of the
governing body’s composition as recognized on 13th June, 2018.
Therefore, it is reiterated that the observations made by this Court are
limited to assessing the jurisdiction and actions of the Registrar of
Societies and should not be construed as reflecting any opinion on the
validity of the minutes of the meeting dated 13th June, 2018. These
issues remain within the purview of the civil court.”
33. In Employees Welfare Forum & Ors. v. Registrar Of Societies
Central & Ors., 2024:DHC:8242, this Court has observed as under -
“6. The stand taken by the Registrar of Societies is in consonance with
the view taken by this Court in several decisions. In Maheshwari
Mandal (Delhi) v. The State of Delhi & Ors. after examining the
CONT.CAS(C) 685/2025 & Connected Matters Page 24 of 31
scheme of the Societies Registration Act, the Court conclusively held
that on a plain reading of Sections 12, 12A, 12B and 12C of the
Societies Registration (Delhi Amendment) Act, 1954, 7 in conjunction
with Section 3 of the Societies Registration Act, does not empower the
Registrar of Societies to adjudicate any issues with regard to the
amendment of any purpose or object of the society. The relevant
portion of the said judgment is as follows:
“7. It is apparent from the plain reading of the sections12,
12A, 12B and 12C of the Act read with section 3 of the Act
that the Registrar does not have any power to adjudicate
any issues with regard to the amendment of any purpose
or object of the society. However, in terms of Section 12A
of the Act, the Registrar has the power to review
registration of the change in name of a society if in its
opinion the same resembles or is identical to the name of
any existing society.
8. At this stage it is also relevant to mention that a Division
Bench of this Court in Dushyant Sharma v. Haryana
Wrestling Association & Ors: LPA No. 18/2012, decided on
10.01.2012 had observed that section 12 of the Act enabled
a society to alter or amend its objects and purpose and did
not extend to registering any amendment in Rules and
Regulations of the society.
9. The learned counsel appearing for the respondent was
also unable to point out any provision in the Act which
empowers the Registrar to perform any adjudicatory
function in respect of the disputes raised by the petitioner.
10. Mr Abhinav Vasisht, learned Senior Advocate
appearing for the petitioner also pointed out that where
ever the State Legislatures intended the Registrar to
perform any adjudicatory function, the State Legislatures
had enacted express provisions in that regard. He referred
to the provisions of Section 12D of the Act as applicable in
the State of Uttar Pradesh. The said section reads as
under:-
“12D. Registrar's power to cancel registration in certain
circumstances.-(1) Notwithstanding anything contained in
this Act, the Registrar may, by order in writing, cancel the
registration of any society on any of the following grounds:-
(a) that the registration of the society or of its name or
change of name is contrary to the provisions of this Act or
of any other law for the time being in force; (b) that its
activities or proposed activities have been or are or will be
subversive or the objects of the society or opposed to public
policy; (c) that the registration or the certificate of renewal
CONT.CAS(C) 685/2025 & Connected Matters Page 25 of 31
has been obtained by misrepresentation of fraud:”
11. This Court finds much merit in the aforesaid contentions
advanced on behalf of the petitioner. Plainly, the Act as
applicable to Delhi does not include any provision which
entitles the Registrar to cancel a registration once the same
has been granted. As stated above, there is also no
provision which empowers the Registrar to examine and
adjudicate any dispute with regard to any alleged
irregularity in the procedure adopted by the society to
amend its Rules and Regulations.”
7. Having regard to the scheme of the Societies Registration Act, this
Court concurs with the legal position set out in the afore-noted
decision. Significantly, this pertinent issue was not brought to the
notice of the Court at the first instance. No doubt, the impugned order
was passed in compliance with the directions issued by this Court,
nonetheless, it still suffers a jurisdictional error. Further, though the
present petition does not specifically challenge the order dated 15th
February, 2016, it is evident that the said order also delves into the
issue of the validity of amendments—an adjudication that falls beyond
the jurisdictional competence of the Registrar. Therefore, both the
impugned order and the previous order dated 15th February, 2016,
are vitiated by a jurisdictional error and are consequently liable to be
set aside.
8. In light of the foregoing, this Court is of the considered view that
the appropriate remedy for the two factions of the governing body of
JNNYC, who are vying for control of its management, by questioning
the amendments to MoA, lies with the Civil Court of competent
jurisdiction. The Registrar of Societies could not have rendered any
opinion as he lacked jurisdiction.”
34. The legal position therefore stands crystallized as under :-
i. The Registrar of Societies is not vested with authority under Section
12 or any other provision of the Act to intervene in the internal affairs
of a registered society, except in cases involving a clear statutory
violation. Even under Section 12A of the Act, the Registrar’s
jurisdiction is narrowly circumscribed and is confined solely to
examining the registration of a proposed change of name, and that too
CONT.CAS(C) 685/2025 & Connected Matters Page 26 of 31
only where such name is identical with or deceptively similar to the
name of an existing society.
ii. Disputes concerning the affairs of a society registered under the Act
must necessarily be instituted before and adjudicated by a competent
civil court, as reinforced by Sections 13 and 14 of the Act and the
consistent judicial precedents on the issue.
iii. Writ jurisdiction cannot be invoked to resolve such disputes, nor can
mandamus be issued in absence of a statutory duty owed by the
Registrar.
35. In view of the aforesaid settled position of law, the reliefs sought by
the petitioner, which squarely impinge upon the internal affairs of the
concerned society, are not maintainable under Article 226 of the
Constitution of India. Issues as regards the petitioner’s claim to be named as
caretaker of RVK; challenges to the sale deed of Patna ashram property;
alleged irregularities in alienation, mutation, transfer, construction or
demolition of properties; allegations of fictitious membership, or claims that
the society has become defunct, are all matters concerning the internal
affairs of the society. Any grievance in respect thereof can only be examined
by a competent civil court having jurisdiction.
36. Thus this Court has no jurisdiction to adjudicate upon the said issues.
The petitioner is, however, at liberty to avail appropriate civil remedies in
accordance with law for redressal of the grievances raised.
37. As regards prayer (b) of W.P.(C) 13723/2025, which pertains to the
impugned notice dated 30.07.2025 issued by the First Appellate Authority,
this Court has considered the petitioner’s grievance that the said notice was
CONT.CAS(C) 685/2025 & Connected Matters Page 27 of 31
dispatched only at 17:01 hours on 21.08.2025, after the date and time fixed
for his appearance, and was in fact delivered to him only on 26.08.2025. In
these circumstances, this Court considers it appropriate to direct the
concerned authorities to reconsider the matter, after affording him a proper
opportunity of being heard.
38. Further, with regard to prayer (a) in W.P.(C) No. 15987 of 2025,
wherein the petitioner seeks directions to the registrar of societies to place
before this Court the resolutions purportedly passed in the Governing Body
meetings of Raj Vidya Kender (RVK), along with all records pertaining to
the erstwhile society, Divine United Organisation (DUO), and its subsequent
change of name to RVK, including complete particulars of all movable and
immovable properties of DUO allegedly transferred, vested, or otherwise
dealt with under RVK, this Court notes that Section 19 of the Societies
Registration Act, 1860 expressly entitles any person to inspect documents
filed with the Registrar under the Act and to obtain certified copies or
extracts thereof.
39. It is, therefore, open to the petitioner to seek inspection and certified
copies of such documents as are available on record with the Registrar of
Societies. However, this Court cannot issue directions to the Registrar of
Societies, NCT of Delhi, to conduct an inquiry into the affairs of RVK or to
take consequential actions such as cancellation of registration (prayer b in
W.P.(C) No. 15987 of 2025).
40. The present petitions are disposed of in the aforesaid terms. It is
clarified that nothing stated herein shall be construed as an expression of
opinion on the merits of the petitioner’s allegations. The Registrar of
Societies shall, however, continue to ensure regulatory oversight and
CONT.CAS(C) 685/2025 & Connected Matters Page 28 of 31
compliance with the Societies Registration Act, 1860 strictly within the
statutory framework.
41. All the other applications filed by the petitioner including CM
APPL.38858/2025 in W.P.(C) 2902/2025 also stand disposed of.
CONT.CAS(C) 685/2025
42. The present petition has been filed by the petitioner seeking the
following reliefs.
43. Vide order dated 07.03.2025 passed in W.P. (C) 2902 of 2025, this
Court had issued the following directions –
1. Issue notice to the respondents, on necessary steps being taken by the
petitioner, through all permissible modes, including electronically. Dasti
in addition.
2. Let the notice indicate that reply be filed by the respondents within a
period of three weeks from the receipt of notice. Rejoinder thereto, if any,
be filed within a period of one week thereafter.
3. List on 21.04.2025.
4. In the meantime, status quo shall be maintained as regards the
immoveable properties of the respondent no.1.
44. Subsequently, CM APPL. 22817/2025 was filed by Raj Vidya Kender
seeking vacation of the ex parte ad-interim status quo order granted on
CONT.CAS(C) 685/2025 & Connected Matters Page 29 of 31
07.03.2025. After hearing the parties, the said application was allowed, and
the status quo order operating in favour of the petitioner was vacated vide
order dated 19.05.2025. The order dated 19.05.2025 is reproduced as under
–
1. This is an application seeking vacation of directions contained in the
order dated 07.03.2025, wherein, it has been, inter alia, directed that the
respondent no.1 shall maintain status quo as regards the immoveable
properties of the respondent no.1.
2. Learned counsel for the respondent no.2/ Raj Vidaya Kender society
(Red. No. 8845/1977) submits that the petitioner is guilty of concealment
of the material facts in the present petition and the concerned society has
been existing for a long period of time and is quite reputed.
3. He submits that affairs of the respondent no.2 have been conducted in
a manner which is perfectly consistent with law and in compliance with
the requirements of the Societies Registration Act, 1860.
4. He draws attention to other previously instituted litigations between
the petitioner and the respondent no.2, wherein, strong observations
have made by this Court as regards the conduct of the present petitioner.
In particular, attention is drawn to the judgment dated 17.04.2025 in
W.P.(CRL) 3931/2024 passed by a co-ordinate Bench of this Court, in
which, it has been found that the petitioner has made reckless allegations
against the Advocate who appeared against him on behalf of the
respondent no.2. Findings have been rendered as regards the conduct of
the petitioner and as regards suppression of material facts.
5. Importantly, attention is drawn to a communication dated 19.03.2025
addressed by the petitioner in the aftermath of the aforesaid order dated
07.03.2025 passed by this Court wherein it has been stated as under:-
“NOTICE TO ALL CONCERNED MEMBERS OF RVK
SOCIETY
To: All Concerned Members of RVK Society
Date-19.03.2025
Re: Maintenance of Status Quo regarding Immovable
Property of RVK Society
CONT.CAS(C) 685/2025 & Connected Matters Page 30 of 31
This is to inform you that the Hon’ble Delhi High Court has
passed an order dated 7.3.2025, in W.P. ( c ) No. 2902/2025
directing that the status quo be maintained with regards to
the immovable property of RVK Society.
In accordance with the Court’s order, it is hereby notified
that:
- The immovable property of RVK Society shall remain in its
current state, and changes or alterations shall be made
thereto.
- No transfer, sale, or alienation of the immovable property
shall be permitted until further orders from the Court.
- All members of the Society are directed to comply with the
Court’s order and maintain the status quo.
Please take note of this important development and ensure
compliance with the Court’s directives.
Sd/-
Sincerely,
Satya Prakash Ravidas
Through Petitioner in Person W.P.( c ) No.2902/2025
Pursuant to the dated 7.3.2025 in W.P. ( c ) No.2902/2025 of
the Hon’ble Court, I am hereby deemed to be the caretaker of
RVK.”
6. As such, the petitioner has sought to project the interim order to imply
that he has been appointed as the caretaker of the respondent no.2. The
same clearly amounts to a mischievous misrepresentation thereof.
7. Learned counsel for the Registrar of Societies/respondent no.1 also
points out that the petitioner has filed multiple petitions with regard to
the respondent no.2 making vague and frivolous allegations having no
merit at all. He points out that the Registrar has duly disposed of the
representation/s of the petitioner in terms of the previously instituted
petition filed by the petitioner before the Telangana High Court being
Writ Petition No.: 8685 of 2024.
8. Learned senior counsel for the respondent no.2 also draws attention to
a communication addressed by the respondent no.2 to the respondent
no.1 on 02.01.2025, wherein, it is recorded that the elections of the
respondent no.2 were duly held on 10.12.2024 and the concerned office-
bearers were duly elected.
CONT.CAS(C) 685/2025 & Connected Matters Page 31 of 31
9. Considering the aforesaid circumstances, particularly the submission
of learned counsel for the respondent no. 1 that there is nothing amiss
about the state of affairs of the concerned society, the interim order dated
07.03.2025 is vacated.
10. However, while vacating the interim order, it is made clear that all
rights and contentions of the petitioner are left open to be considered at
the time of final disposal of the writ petition, on the next date of hearing.
11. The application stands disposed of.”
45. In view of the above, once the very order that forms the foundation of
the present contempt petition stands vacated, and in view of dismissal of
W.P.(C) 2902/2025, no cause for contempt survives. Consequently, the
petition is dismissed.
SACHIN DATTA, J
FEBRUARY 2, 2026/sv
Legal Notes
Add a Note....