Madhya Pradesh High Court

Revived societies with fresh management cannot be disqualified for irregularities committed by predecessor dissolved committees.

Fauzi Adarsh Primary Consumer Cooperative Siciety Registered For Ward No. 6 And 7 Radhogarh Distt vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: April 06, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner is a cooperative society registered under the M.P. Co-operative Societies Act, 1960

Source reference: p. 2

Its previous allotment of a fair price shop (FPS) was cancelled in 2010 due to irregularities by former staff, and the society subsequently went into liquidation in 2017

Source reference: p. 2

On 21.08.2023, the Deputy Registrar, Co-operative Societies revived the society and a new management committee was constituted

Source reference: p. 2

In January 2025, the State invited applications for FPS allotments.

Source reference: no citation

The Petitioner’s application was rejected as ineligible on 04.03.2025, citing the 2010 irregularities, while Respondent No. 6 was declared eligible

Source reference: p. 3

The Petitioner filed objections on 07.03.2025, but the authorities recorded a false note on 10.03.2025 claiming no objections were received

Source reference: p. 3

Respondent No. 6, registered for Ward No. 2, was granted allotment for Wards No. 6 and 7

Source reference: p. 3

The Petitioner challenged these orders before the High Court under Article 226/227.

Source reference: no citation
02

Issues

1. Whether the past irregularities of a dissolved management committee can be attributed to a revived society with a reconstituted management under the M.P. PDS (Control) Order, 2015?

Source reference: p. 7

2. Whether the allotment of a fair price shop to a society whose registered working area does not include the designated wards is legally sustainable?

Source reference: p. 3, 8

3. Whether the administrative action of ignoring timely objections and recording false statements in official note-sheets violates the principles of natural justice?

Source reference: p. 8
03

Law Applied

M.P. Public Distribution System (Control) Order, 2015, specifically Clause 8(1) regarding eligibility and its provisos, which state that a society may be eligible if the guilty office bearers have been removed

Source reference: p. 7

Clauses 8(2) and 8(4), which prohibit institutions from operating fair price shops beyond their notified operational areas

Source reference: p. 2, 7

Precedent established in Writ Petition No. 4879/2012 (affirmed in Writ Appeal No. 458/2012), which held that no institution can operate an FPS outside its operational jurisdiction

Source reference: p. 3
04

Reasoning

The Court reasoned that since the Petitioner society was revived with a completely fresh committee following liquidation, the second proviso to Clause 8(1) of the 2015 Order applies, making the society eligible for fresh consideration regardless of the 2010 irregularities

Source reference: p. 7

The Court found the respondents' reliance on the repealed 2009 Order to disqualify the Petitioner to be legally untenable

Source reference: p. 8

The Court observed a gross violation of natural justice, as the authorities disregarded the Petitioner’s timely objections and made a false entry in the official records stating no objections were received

Source reference: p. 8

Regarding the operational area, the Court noted that Respondent No. 6’s registration for Ward No. 2 did not clearly extend to Wards No. 6 and 7, rendering the allotment process non-transparent and potentially in violation of statutory limits

Source reference: p. 8
05

Holding

The Court held that the Petitioner is entitled to a fresh, transparent consideration of its application under Clause 8 of the 2015 Order

The Court allowed the writ petition and set aside the impugned orders dated 04.03.2025, 10.03.2025, and 01.08.2025 to the extent they rejected the Petitioner’s claim

Source reference: p. 9

The matter was remanded to the respondents to re-examine the application and conduct a factual verification of Respondent No. 6's operational area limitations

Source reference: p. 8-9

The respondents were directed to complete this exercise within three months

Source reference: p. 9
Madhya Pradesh High Court

Original Court PDF

Fauzi Adarsh Primary Consumer Cooperative Siciety Registered For Ward No. 6 And 7 Radhogarh DisttvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · April 06, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment