Madhya Pradesh High Court Administrative and Public Law Constitutional Law

MP HC Directs Registrar To Conclude Enquiry Into Cooperative Assistant Manager’s Alleged ₹47.19 Lakh Audit Recovery After Hearing Him, Preferably Within Four Weeks

Om Prakash Sahuv.State Of Madhya Pradesh

By LawLens Team · Editorial and Research TeamDecided November 04, 2026Published 5 November 2026 at 1:36 pm IST2 min read

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In brief

The question

1. Whether the Court should direct the District Registrar to conclude the enquiry concerning the allegations against the petitioner after affording him an opportunity of hearing.

The court held

The Court disposed of the petition and directed the District Registrar, Cooperative Societies, Gwalior, to conclude the enquiry concerning the petitioner, preferably within four weeks of receiving a certified copy of the order, pass an appropriate order in accordance with law, and communicate the outcome to the petitioner.

It also directed

The Court expressed no opinion on the merits.

01Facts

The petitioner, an Assistant Society Manager, challenged an audit report based on an ex parte enquiry that attributed approximately ₹47,19,841.75 in recoveries to him.

p. 1

He stated that he had complained on 15 March 2023 seeking a fair enquiry and an opportunity to be heard; the matter was forwarded to the District Registrar, Gwalior, on 14 August 2023, but the enquiry remained unresolved and its outcome had not been communicated to him.

p. 1

The State submitted that the competent authority would examine the grievance under the applicable law.

pp. 1–2

02Issues

i.1. Whether the Court should direct the District Registrar to conclude the enquiry concerning the allegations against the petitioner after affording him an opportunity of hearing.

pp. 2–3

ii.2. Whether the Court should express any view on the merits of the allegations or the audit report while granting that direction.

p. 3

03Law Applied

The petition was brought under Article 226 of the Constitution of India, which empowers the High Court to issue appropriate directions.

p. 1

The Court directed that the enquiry be conducted in accordance with law and after affording the petitioner a due opportunity of hearing.

p. 3

No statute or judicial precedent was cited in the order.

p. 1, 3

04Reasoning

The Court treated the petitioner’s principal grievance as the prolonged non-conclusion of an enquiry referred to the competent authority and his lack of an effective hearing or communication of the outcome.

p. 2

Given the limited relief sought, it considered it appropriate to direct the District Registrar to complete the enquiry lawfully and after hearing the petitioner, while expressly declining to assess the allegations or the audit report’s correctness.

p. 3