An appeal lies to the Registrar against a Zonal Joint Registrar’s appointment of a One-Man Committee.

The petitioners, shareholders of Rongpur Cooperative Society Ltd., challenged the Registrar of Cooperative Societies’ order dated 10 July 2026, by which the Managing Committee/Board of Directors of the Society was reinstated after the Zonal Joint Registrar had dissolved the Committee and appointed a One-Man Committee under Section 41(6) of the Assam Cooperative Societies Act, 2007.

The dissolution-related action had been initiated on the ground that the Annual General Meeting for the cooperative year 2022–23 had not been convened in accordance with Section 39 of the Act.

Respondent No. 6 preferred an appeal, and the Registrar, relying on a written report, found that a new Board had already assumed office on 28 April 2023 for a five-year term covering 2023–24 to 2027–28.

The Registrar held that the new Board could not be penalised for the alleged negligence of the earlier supervising officer and consequently reinstated it.

Whether the Registrar of Cooperative Societies had jurisdiction under Section 111(1) of the Assam Cooperative Societies Act, 2007 to entertain and decide the appeal against the order passed by the Zonal Joint Registrar appointing a One-Man Committee.

Whether the dissolution of the Managing Committee and the consequential appointment of the One-Man Committee were legally sustainable where the Annual General Meeting for 2022–23 had not been held under Section 39 of the Act.

Whether the Registrar was justified in reinstating the existing Managing Committee/Board of Directors on the ground that the new Board could not be penalised for the earlier supervisory officer’s negligence.

The Court applied Section 39 of the Assam Cooperative Societies Act, 2007, concerning the holding of the Annual General Meeting; Section 41(6), under which the competent cooperative authority may appoint a One-Man Committee in the prescribed circumstances; and Section 111(1), which provides an appellate remedy to the Registrar against an order passed by the Zonal Joint Registrar.

The Court further held that, where the statutory consequence follows by operation of law, the Registrar retains authority to determine whether Section 39 was attracted and to adjudicate the consequential appeal.

The Court rejected the petitioners’ jurisdictional objection on both factual and legal grounds.

Factually, the order appointing the One-Man Committee had been passed by the Zonal Joint Registrar, not by the Registrar of Cooperative Societies; therefore, an appeal to the Registrar under Section 111(1) was maintainable.

Legally, the Court held that the dissolution of the Managing Committee occurred by operation of law based on the alleged non-compliance with Section 39, enabling the Registrar to determine whether that statutory consequence applied.

The Registrar had also considered that the new Board had assumed office before the relevant AGM period and that the alleged default was attributable to the earlier supervisory arrangement, not the newly constituted Board.

On that basis, reinstatement of the Board was found justified.

Finding no merit in the writ petition, the Court dismissed it and vacated the interim order previously granted.