Statutory membership findings cannot be challenged indirectly when primary enquiry conclusions attained finality through non-challenge.

The Petitioner No. 1 is a society registered in 2002 under the M.P. Society Registrikaran Adhiniyam, 1973.

Petitioner No. 2 claimed to be the President and manager of the society’s educational institutions.

Disputes arose in 2014 when Respondent No. 4 (then Secretary) allegedly sought closure of the institutions, leading the Executive Committee to terminate his membership in 2016.

Respondent No. 4 alleged that Petitioner No. 2 was removed by the General Body.

An enquiry under Section 32 of the Act revealed that neither faction could produce the original membership register or establish the legality of their membership.

Consequently, the Assistant Registrar's initial order was set aside by the Registrar (Respondent No. 2) on 26.10.2023, who directed that management be handed over to the seven original founder/life members.

This was affirmed by the State Government (Respondent No. 1) on 29.01.2025.

1. Whether the appellate authorities were justified in vesting management in the founder members despite the absence of an original membership register.

2. Whether the writ petition was maintainable given that Petitioner No. 2’s status as a valid member/President was unproven and successfully challenged below.

The court primarily applied the M.P. Society Registrikaran Adhiniyam, 1973, specifically Section 16, which dictates that the register of members constitutes prima facie evidence of membership.

Section 32 regarding the Registrar's power to enquire into society affairs.

Section 27 regarding the filing of the list of the governing body.

The court relied on the precedent Edukanti Kistamma (Dead) v. S. Venkatareddy (Dead), which mandates a purposive interpretation of beneficial statutes to advance the legislative intent and ensure administrative stability.

Principles of Judicial Review under Article 226, limiting interference to cases of perversity, jurisdictional error, or violation of natural justice.

The court found that the Petitioner No. 2 failed to challenge the initial enquiry findings which concluded that he had not established his valid membership.

The court rejected the argument that annual returns or RTI documents could override the necessity of an original membership register in a factional dispute.

Regarding the "founder members," the court noted that under the society’s bye-laws, these individuals were "life members" and not subject to cessation for non-payment of annual subscriptions.

The court reasoned that since neither rival faction could prove subsequent membership inductions, the Registrar acted within his jurisdiction to restore management to the original undisputed life members to avoid an administrative vacuum.

The court observed that Petitioner No. 2 lacked locus standi to represent the society as "President" when the statutory records under Section 27 recognized a different governing body.

The court held that management of a society's institutions is an incident of lawful control over the society itself, which the petitioners failed to prove via statutory membership records.

The final holding affirmed the orders dated 26.10.2023 and 29.01.2025, dismissing the writ petition and maintaining the management of the society under the seven life/founder members.