A completed receiver-supervised election precludes restoration of the former committee’s management.

The appeal arose from the dismissal of the appellants’ application under Order XL Rules 3 and 4 read with Section 151 CPC, which sought, among other reliefs, to challenge the inclusion of 11 persons in the Sabha’s voter list and to secure payment of its expenses.

The underlying suit challenged the appellants’ claimed election to the Sabha’s Managing Committee on 9 November 2025.

In that suit, the Trial Court restrained both factions from managing the Sabha and appointed a neutral Receiver to conduct fresh elections.

The Receiver conducted elections on 12 July 2026, and the Trial Court recorded the result on 18 July 2026.

Before the High Court, the appellants did not press their challenges to the voter list or the fresh election; they sought only to have the 2025 Managing Committee manage the Sabha until 9 November 2026, or alternatively to have the Receiver continue managing its affairs until then.

1. Whether the Managing Committee elected on 9 November 2025 should be permitted to manage the Sabha until 9 November 2026, notwithstanding the Receiver-supervised election and the resulting new Managing Committee.

2. Whether, in the alternative, the Receiver should continue to manage the Sabha’s affairs until 9 November 2026.

Order XL Rule 1 CPC permits appointment of a Receiver where the circumstances warrant neutral judicial intervention to protect property or administration in dispute; Order XL Rules 3 and 4 and Section 151 CPC were invoked in the appellants’ application concerning the Receiver’s duties.

The Trial Court’s operative directions restrained both factions from managing the Sabha and appointed the Receiver for the limited purpose of conducting fresh elections; the restraint was to continue until disposal of the suit or declaration of the election result, whichever occurred earlier.

The High Court cited no separate precedent or broader statutory rule in deciding the limited relief that remained pressed.

The Receiver had been appointed because competing claims to control of the Sabha had impaired its functioning, and the Trial Court had deliberately avoided placing management in either faction’s hands while fresh elections were conducted.

The appellants had not challenged the appointment order, had participated in the process, and did not press their challenge to the fresh election in this appeal.

Once the election process had produced a new Managing Committee, permitting the former committee to resume management—or extending the Receiver’s role on the requested basis—would undo the election exercise set in motion by the Trial Court.

The Court therefore declined to grant either alternative, while reserving the merits of the election and voter-list disputes for the pending proceedings.

It expressed no opinion on the validity of the elections held on 9 November 2025 and 12 July 2026 or on the inclusion of the 11 disputed voters, leaving those matters for determination in the pending proceedings.

The Court also continued its 15 September 2026 direction requiring the respondents to maintain the details of the Sabha’s three bank accounts in the usual course of business, during the suit or until fresh elections, whichever occurred earlier.