Education Authorities Lack Jurisdiction to Appoint Administrators Over Trusts Registered Under Maharashtra Public Trust Act.

The Petitioner, a former member of the Kasare Education Society (Respondent No. 5), filed a writ petition seeking the appointment of an administrator over the Society and its school (Respondent No. 6)

The Petitioner alleged that the trustees lacked authority to conduct recruitment because their Change Reports had been rejected by the Assistant Charity Commissioner

He further claimed that despite filing several complaints with educational authorities regarding illegal acts and financial mismanagement, no concrete action was taken following an inquiry report dated July 9, 2025

The State opposed the petition, questioning the Petitioner’s locus standi and the maintainability of the writ

1. Whether the High Court should exercise its writ jurisdiction under Article 226 to appoint an administrator over a public trust based on disputes regarding the authority of its trustees

2. Whether educational authorities have the jurisdiction to interfere with the internal administration and management of a Trust registered under the Maharashtra Public Trust Act, 1950

The court applied the jurisdictional framework of the Maharashtra Public Trust Act, 1950, noting that the Charity Commissioner is the competent authority for the administration of trusts

It further referred to the Maharashtra Employees of Private Schools (Conditions of Service) Regulation Act (MEPS Act) and the School Code, which govern school administration and the limited scope of inquiry for educational authorities

The court emphasized the limits of judicial review under Article 226 of the Constitution of India regarding internal trust disputes where alternative remedies exist

The Court reasoned that the Petitioner’s grievances primarily concerned the legal status of the trustees following the rejection of Change Reports, a matter squarely within the jurisdiction of the Charity Commissioner, not educational authorities

The Court found that the Petitioner failed to demonstrate any specific procedural illegality in school management that would justify interference by the Education Officer

It noted that the Petitioner’s reliance on recent representations and a preliminary inquiry report did not provide a prima facie case for the extreme measure of appointing an administrator

The Court held that educational authorities' jurisdiction is circumscribed to academic and procedural rules of the school and does not extend to the overall control of a Trust registered under the 1950 Act

The Court dismissed the Writ Petition but allowed educational authorities to deal with any pending inquiry reports strictly within their own jurisdiction and as per legal procedure