Supply of milk failing prescribed quality standards justifies exclusion from minimum volume requirements for electoral eligibility.

The Appellant, a primary milk producers co-operative society and member of the Respondent No. 5 Union (a Federal Society), challenged its inclusion in the "ineligible voters list" for the Union's board elections

The Union issued show-cause notices alleging the Appellant failed to supply the minimum requisite quantity of milk (150 Kgs/day for 270 days) for the years 2020-21 and 2022-23, as mandated by Bye-laws 15.2 and 15.3

The Appellant contended that it supplied the bulk quantity, but the Union improperly excluded milk batches with a Solids-Not-Fat (SNF) value below 8.5%

A Single Judge dismissed the writ petition, holding that the Union followed due process under Rule 13-D(2-A) of the KOS Rules and that disputes regarding milk quality were factual matters for arbitration under Section 70

Whether the Union was justified in excluding milk supplies with an SNF value below 8.5% when calculating the minimum supply requirements for voting eligibility under Bye-law 15.2

Whether the amendment to Bye-law 15.2 could be applied retrospectively to disqualify a member based on past performance

Whether the High Court should interfere under Article 226 regarding the technical determination of milk quantity and quality in election matters

The Court applied Section 20(2)(a-v) of the Karnataka Co-operative Societies (KOS) Act, 1959, which defines the eligibility of a member to vote based on the utilization of minimum services

It relied on Bye-laws 13.1(a) and 15.2 of the Union, which mandate the supply of "quality milk" (minimum 150 Kgs/day for 270 days) as a precondition for voting rights

Procedurally, the Court looked to Rule 13-D(2-A) of the KOS Rules, 1960, regarding the preparation of the ineligible voters list

The Court reasoned that Bye-law 13.1(a) specifically requires the supply of "quality milk," which by established industry standards (prescribed by the Apex Milk Union) must maintain an SNF value of 8.5% or above

Consequently, milk failing this standard does not qualify as the "service" envisioned under the KOS Act or the Union’s Bye-laws

Regarding the calculation of the deficit, the Court found the Union’s method—proportionately reducing the accounted quantity for sub-standard milk—was not arbitrary as it was applied uniformly to all members

The Court further noted that the scope of judicial review under Article 226 is limited in election matters; since the Union complied with the procedural requirement of issuing show-cause notices under Rule 13-D(2-A), the underlying factual dispute regarding milk adulteration or SNF testing was a matter for statutory arbitration under Section 70(2)(c) of the KOS Act rather than writ jurisdiction

The Court affirmed that conforming to SNF standards is a valid prerequisite for counting milk supplies toward election eligibility

It clarified that questions regarding the prospective or retrospective application of amended bye-laws were secondary to the fact that the disqualification was consistent with the parent statute, Section 20(2)(a-v) of the KOS Act

Final relief was denied, and the findings of the Single Judge were upheld