Patna High Court
Tax LawAdministrative and Public Law

Registered cooperative societies are exempt from stamp duty and registration charges.

Sahebganj Nav Yatayat Sahyog Samitee Ltd. vs The State of Bihar

Patna High CourtJUDGMENT: July 27, 20263 MIN READSOURCE JUDGMENT
Registered cooperative societies are exempt from stamp duty and registration charges.. Sahebganj Nav Yatayat Sahyog Samitee Ltd. vs The State of Bihar. Patna High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a registered co-operative society, was awarded the Sahebganj–Manihari inter-state ferry-ghat transportation contract for the financial years 2022–2023 and 2023–2024.

Source reference: p.2

The District Magistrate, Katihar issued Letter No. 284 dated 5 February 2024 demanding, inter alia, ₹1,36,32,000 towards registration charges and stamp duty for the two financial years, in addition to a separate default settlement amount of ₹1,26,00,000.

Source reference: p.3

The petitioner challenged the demand for stamp duty and registration charges, relying on Memo No. 141 dated 4 November 1986 and Memo No. 2933 dated 4 November 2019, and on the decision in Ganga Koshi Navik Naw Yatayat Samittee in CWJC No. 2010 of 2020.

Source reference: p.4

The State contended that the petitioner had participated in an open bid and, being the highest bidder, was not entitled to preferential exemption. It also relied on a Four-Member Committee report formed after the Court’s order dated 13 February 2025.

Source reference: p.4
02

Issues

Whether a registered co-operative society is exempt from payment of stamp duty and registration charges in respect of the ferry-ghat settlement in question.

Source reference: pp. 4–5

Whether the demand of ₹1,36,32,000 raised through Letter No. 284 dated 5 February 2024 towards stamp duty and registration charges was legally sustainable despite the petitioner’s participation in an open bid.

Source reference: pp. 3–5
03

Law Applied

The Court relied on Memo No. 141 dated 4 November 1986 issued by the Joint Secretary, Revenue and Land Reforms Department, Government of Bihar, and the subsequent policy decision contained in Memo No. 2933 dated 4 November 2019, which exempt co-operative societies from payment of stamp duty and registration charges.

Source reference: p.4

It also followed the co-ordinate Bench’s decision dated 3 April 2023 in CWJC No. 2010 of 2020, holding that co-operative societies are entitled to such exemption.

Source reference: p.6

The Court further relied on the Division Bench decision in Patliputra Cooperative Housing Construction Society Limited v. State of Bihar & Others, reported in 1977 BBCJ 76, and the opinion of the learned Advocate General dated 28 June 2023, which affirmed that co-operative societies are exempt from stamp duty.

Source reference: p.6
04

Reasoning

The Court treated the petitioner’s status as a registered co-operative society as determinative of its entitlement to exemption.

Source reference: p.6

It held that the earlier decision in CWJC No. 2010 of 2020 had already clarified that co-operative societies were exempt from stamp duty and registration charges.

Source reference: p.6

The State’s reliance on the petitioner’s participation in an open bid and its status as the highest bidder did not displace the exemption, particularly when the State’s own supplementary counter-affidavit referred to the Advocate General’s opinion affirming the exemption under Memo No. 2933 of 2019 and the Patliputra Cooperative Housing Construction Society decision.

Source reference: p.6

Accordingly, the demand raised under Letter No. 284, to the extent it concerned stamp duty and registration charges, was found unsustainable.

Source reference: p.6
05

Holding

The Court answered the issues in favour of the petitioner and held that, being a registered co-operative society, it was exempt from stamp duty and registration charges.

Letter No. 284 dated 5 February 2024 was quashed to the extent it demanded ₹1,36,32,000 towards those charges.

Source reference: p.6

The Court further clarified that any proceeding initiated pursuant to that demand, insofar as it related to stamp duty and registration charges, would be futile.

Source reference: p.6

The writ petition was accordingly disposed of.

Source reference: p.6
Patna High Court

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Sahebganj Nav Yatayat Sahyog Samitee Ltd.vsThe State of Bihar

Patna High Court · July 27, 2026

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