Charity Commissioner possesses statutory authority to appoint interim committees and scrutinize voters' lists upon trust tenure expiry.

The petitioners challenged two orders dated March 13, 2026, passed by the Charity Commissioner regarding the administration of the Asiatic Society of Mumbai

The Society’s managing committee elections held in September 2023 were rejected by the Assistant Charity Commissioner in August 2025

Despite their tenure expiring and the rejection of the Change Report, the committee continued to function, declaring an election program and admitting 1,467 new members through a Scrutinizing Committee whose term had also expired

Following Legislative Assembly Questions regarding missing books and voter list discrepancies, an Inspector's report confirmed 2,050 missing books and procedural illegalities

Consequently, the Charity Commissioner stayed the scheduled March 2024 elections and appointed a committee—including a "fit person"—to manage day-to-day affairs and finalize a valid voters' list

1. Whether the impugned orders were passed in violation of the principles of natural justice due to lack of notice or hearing

2. Whether the Managing Committee had the legal authority to continue functions and admit new members after the rejection of their Change Report and the expiry of their tenure

3. Whether the Charity Commissioner possessed the statutory jurisdiction to appoint a "fit person" and interfere with the Society's electoral process

The Court applied Section 30A of the Maharashtra Public Trusts Act, 1950, which stipulates that trustees cease to perform functions upon the expiry of their tenure unless re-appointed

Sections 3, 36A, and 69 of the Act, which grant the Charity Commissioner plenary powers of superintendence and the authority to issue directions for the effective administration of public trusts

Section 47 of the Act was applied, authorizing the Commissioner to make interim arrangements for trust management to ensure smooth functioning in the absence of a legally constituted committee

The Court rejected the petitioners' claim of natural justice violations, noting that the Charity Commissioner held multiple hearings (March 5, 9, 11, and 12, 2026) where office bearers were present and represented by counsel

On the merits, the Court found that the Managing Committee and Scrutinizing Committee became functus officio following the rejection of the Change Report on August 6, 2025, and the expiry of their terms in September 2025

The Court reasoned that the Charity Commissioner acted within his statutory mandate under Sections 36A, 47, and 69 to prevent patent illegalities and protect the trust's assets, especially following the Inspector’s report on missing books and voter list manipulation

The Court affirmed the Commissioner’s order staying the election resolution of February 20, 2026, and upheld the interim arrangement of a "fit person" committee to finalize a valid voters' list and oversee new elections. All ad-interim reliefs were vacated, and the request for a stay on this judgment was rejected