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Issues:
1. Jurisdiction of the civil court in a suit challenging the election of a managing committee of a registered society. 2. Interpretation of Sections 23 and 25 of the Registration Act in relation to the maintainability of the suit. 3. Application of the legal principles regarding exclusion of jurisdiction of the civil court. Analysis: 1. The case involved a society registered under the Societies-Registration Act, where certain members challenged the election of the managing committee and sought rendition of accounts in a civil court. The central issue was whether such a suit was maintainable in the civil court, as per the provisions of Sections 23 and 25 of the Registration Act. The lower courts had allowed the suit to proceed, leading to an appeal to the Supreme Court. 2. The Supreme Court emphasized that a litigant has the right to approach a civil court unless jurisdiction is expressly or impliedly barred. Referring to legal precedents, it was established that the exclusion of civil court jurisdiction should not be readily inferred and must be clearly indicated by law. The Court highlighted the need for a careful analysis of the Registration Act's provisions to determine the suit's maintainability. 3. The Court examined Sections 23 and 25 of the Registration Act, which deal with audit requirements and disputes regarding the election of office-bearers, respectively. It was clarified that Section 23 pertained to audit matters and did not address the relief of rendition of accounts sought in the suit. Regarding Section 25, which governs disputes related to office-bearer elections, the Court noted that specific conditions must be met for a statutory dispute to be maintainable. In this case, the members challenging the election may not fulfill the requirements of Section 25, making their suit permissible in the civil court. 4. The Court concluded that the suit challenging the election of office-bearers was maintainable in the civil court, as the conditions under Section 25 were not met by the members. It was also highlighted that the relief sought fell within the ambit of Section 9 of the Civil Procedure Code. The Court directed the trial court to expedite the suit's disposal, considering the annual nature of the elections and any changes in circumstances. The appeal was dismissed, with no costs awarded. Conclusion: The Supreme Court affirmed the maintainability of the suit challenging the election of office-bearers of a registered society in a civil court, based on the interpretation of relevant provisions of the Registration Act. The judgment clarified the application of legal principles regarding civil court jurisdiction and directed the trial court to promptly address the suit's disposition.
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