Writ Petition challenging internal election disputes of a private society is not maintainable under Article 226.

The petitioners, members of the Satna Divisional Cricket Association (SDCA), challenged an election notification dated 13.04.2026, which scheduled elections for 03.05.2026.

The petitioners alleged that an Ad-hoc Committee, including Respondents No. 7 and 8 (who had previously acted as inquiry officers), was biased, improperly constituted, and in violation of MPCA recommendation Clause 12.3 regarding neutrality.

They sought a writ of certiorari to quash the election programme and a mandamus to reconstitute the committee and rationalize membership.

The respondents raised a preliminary objection regarding the maintainability of a writ petition against a private society.

1. Whether a writ petition under Article 226 of the Constitution of India is maintainable against a Society regarding internal electoral disputes and membership irregularities

The court applied the principles governing Article 226 of the Constitution of India, which restricts writ jurisdiction to State actors or private bodies performing public functions.

the M.P. Society Registrikaran Adhiniyam, 1973, which provides a statutory framework for resolving disputes within registered societies.

The court distinguished between "public functions" and "inter-se disputes" between members of a private body, holding that the latter does not attract the extraordinary jurisdiction of the High Court.

The court evaluated the petitioners' claim that because the Society performs a "public function," it should be amenable to writ jurisdiction.

the court found that the core of the dispute involved irregularities in membership lists and election procedures.

The court reasoned that these are essentially inter-se disputes between members of a society and do not affect the public at large.

even if the body performs some public-facing roles, the specific grievances raised were internal administrative matters that do not meet the threshold of "public law" functions required for a writ under Article 226.

The court noted that alternative remedies, such as a Civil Suit or a petition before the competent authority under the M.P. Society Registrikaran Adhiniyam, 1973, were available.

The High Court dismissed the writ petition, directing the petitioners to seek relief through a Civil Suit or the competent authority under the M.P. Society Registrikaran Adhiniyam, 1973.