Section 156 bars civil suits challenging cooperative society awards under Section 90.

The plaintiff, a member of the defendant Co-operative Society, borrowed ₹30,000 in 1997, of which ₹5,000 was retained towards his share amount.

He claimed to have repaid ₹31,000 by June 2000 and disputed the Society’s later demand for ₹35,690, asserting that the payments and share amount extinguished any liability.

After the Society issued a demand notice and later initiated recovery proceedings pursuant to an award under the Tamil Nadu Co-operative Societies Act, 1983, the plaintiff sued for rendition of accounts and permanent injunction.

The Trial Court dismissed the suit; the First Appellate Court reversed that decision and granted relief to the plaintiff.

The Society appealed under Section 100 CPC.

1. Whether a civil suit for rendition of accounts and permanent injunction, brought against execution proceedings based on an award under Section 90 of the Tamil Nadu Co-operative Societies Act, 1983, was barred by Section 156 where the plaintiff had not pursued the statutory appellate remedy.

2. Whether the First Appellate Court erred in granting relief when the Society’s claim for debt, including the amount due and applicable interest, fell within Explanation 1(i) to Section 90.

Section 90(1) of the Tamil Nadu Co-operative Societies Act, 1983 requires disputes touching the business of a registered society between the society and its members to be referred to the Registrar; Explanation 1(i) expressly includes a society’s claim for a debt or demand from a member, whether admitted or not.

Section 156 bars civil-court challenges to orders, awards, decisions or actions under the Act and prohibits injunctions concerning matters done or intended to be done pursuant to an order under the Act.

A party aggrieved by an award must pursue the remedies provided by the Act and cannot challenge it indirectly through a civil suit.

The plaintiff’s challenge concerned his liability under the loan, including the amount payable and the calculation of interest—matters falling within the statutory definition of a dispute under Section 90.

An award had been made and recovery proceedings initiated pursuant to it; therefore, any challenge to the award or the amount determined had to be brought through the Act’s statutory remedies.

Because the suit sought to contest the recovery and restrain proceedings taken pursuant to the award, Section 156 barred the civil action.

The Trial Court had correctly dismissed the suit, and the First Appellate Court erred in reversing that decision.

It allowed the second appeal, thereby restoring the Trial Court’s dismissal of the suit, made no order as to costs, and closed the connected miscellaneous petition.