1. Societies registered under state legislation seek clarity on their status as multi-state cooperative societies following the bifurcation of their parent state. (Para 1 , 2 , 3 , 20 )
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2026 Supreme(SC) 237
SUPREME COURT OF INDIA
PAMIDIGHANTAM SRI NARASIMHA, ALOK ARADHE, JJ.
Registrar Cane Cooperative Societies and Others – Appellants
Versus
Gurdeep Singh Narval (Dead) through LRs. and Others – Respondents
Civil Appeal No. 8743 of 2013, Civil Appeal No. 8746 of 2013, Civil Appeal No. 8745 of 2013, Civil Appeal No. 8744 of 2013
Decided On : 10-03-2026
Important Points
Courts must interpret legal fictions strictly, ensuring they do not exceed the legislative intent or conflict with existing statutory frameworks, particularly in cases of state reorganization.
Subject
Cooperative Law - Multi-State Cooperative Societies
Act Referred
Headnote
(A) Uttar Pradesh Reorganisation Act, 2000 - Section 87 - Multi-State Cooperative Societies Act, 2002 - Sections 103 and 93 - Question of legal status of Sugarcane Cooperative Societies on bifurcation of State - Societies not deemed Multi-State due to restrictions on their area of operation and objectives. (Paras 1, 13, 24, 26)
(B) Legal Interpretation - Legal fictions must be confined to their purpose; cannot override statutory provisions. (Paras 22, 24)
Facts of the case:
The appellants challenged the High Court's ruling that certain cooperative societies were Multi-State Cooperative Societies, since reorganization under the Reorganisation Act had already occurred based on geographical criteria. Key modifications were made to the bylaws of these societies, limiting their operations to a single state.
Findings of Court:
The court held that the societies in question could not be classified as Multi-State Cooperative Societies, as their functions and objectives were restricted to one state and reorganization had already been carried out appropriately.
Issues: The core issues revolved around the applicability of Section 103 of the 2002 Act and whether reorganization under the Reorganisation Act had validly isolated the societies to a single state status.
Ratio Decidendi: The court reasoned that Section 103's implications were conditional and did not apply because the societies' operational scope and objectives were only state-specific, thus validly reorganized under the Reorganisation Act.
Result: Appeals allowed and High Court's judgment quashed.
(B) Legal Interpretation - Legal fictions must be confined to their purpose; cannot override statutory provisions. (Paras 22, 24)
Facts of the case:
The appellants challenged the High Court's ruling that certain cooperative societies were Multi-State Cooperative Societies, since reorganization under the Reorganisation Act had already occurred based on geographical criteria. Key modifications were made to the bylaws of these societies, limiting their operations to a single state.
Findings of Court:
The court held that the societies in question could not be classified as Multi-State Cooperative Societies, as their functions and objectives were restricted to one state and reorganization had already been carried out appropriately.
Issues: The core issues revolved around the applicability of Section 103 of the 2002 Act and whether reorganization under the Reorganisation Act had validly isolated the societies to a single state status.
Ratio Decidendi: The court reasoned that Section 103's implications were conditional and did not apply because the societies' operational scope and objectives were only state-specific, thus validly reorganized under the Reorganisation Act.
Result: Appeals allowed and High Court's judgment quashed.
Legal Category Hierarchy
Advocates appeared:
For the Appellant(s) : Mr. Abhishek Atrey, AOR Dr. Abhishek Atrey, Adv. Mr. Vikas Negi, Adv. Ms. Vidyottma Jha, Adv. Mr. Jagdeep Sharma, Adv. Mr. Navneet Gupta, Adv. Dr. Riju Raj S Jamwal, Adv. Mr. Balaji Srinivasan, AOR Mr. Manoj Sagar, Adv. Mr. Dinesh Dwivedi, Sr. Adv. Mr. P.N. Gupta, AOR Mrs. Bharti Gupta, Adv. Mr. Pushp Raj Gupta, Adv.
For the Respondent(s): Mr. T. N. Singh, AOR Mr. Kumar Gaurav, Adv. Ms. Rajshree Singh, Adv. Mr. Umang Tripathi, Adv. Mr. Akshat Kumar, AOR Mr. Abhishek Atrey, AOR Mr. K.M.Nataraj, A.S.G. Mr. Vatsal Joshi, Adv. Mr. Amit Sharma-v, Adv. Mr. Uday Bhan Singh, Adv. Mr. Bhuvan Kapoor, Adv. Mr. Prashant Singh-ii, Adv. Mr. Yogesh Vats, Adv. Dr. N. Visakamurthy, AOR Mr. K.M.Nataraj, A.S.G. Mr. Vatsal Joshi, Adv. Mr. Chitransh Sharma, Adv. Mr. Sharath Nambiar, Adv. Ms. Aashna Gill, Adv. Mr. Santosh Ramdurg, Adv. Mr. Yogesh Vats, Adv. Mr. Shreekant Neelappa Terdal, AOR
For the Appellant(s) : Mr. Abhishek Atrey, AOR Dr. Abhishek Atrey, Adv. Mr. Vikas Negi, Adv. Ms. Vidyottma Jha, Adv. Mr. Jagdeep Sharma, Adv. Mr. Navneet Gupta, Adv. Dr. Riju Raj S Jamwal, Adv. Mr. Balaji Srinivasan, AOR Mr. Manoj Sagar, Adv. Mr. Dinesh Dwivedi, Sr. Adv. Mr. P.N. Gupta, AOR Mrs. Bharti Gupta, Adv. Mr. Pushp Raj Gupta, Adv.
For the Respondent(s): Mr. T. N. Singh, AOR Mr. Kumar Gaurav, Adv. Ms. Rajshree Singh, Adv. Mr. Umang Tripathi, Adv. Mr. Akshat Kumar, AOR Mr. Abhishek Atrey, AOR Mr. K.M.Nataraj, A.S.G. Mr. Vatsal Joshi, Adv. Mr. Amit Sharma-v, Adv. Mr. Uday Bhan Singh, Adv. Mr. Bhuvan Kapoor, Adv. Mr. Prashant Singh-ii, Adv. Mr. Yogesh Vats, Adv. Dr. N. Visakamurthy, AOR Mr. K.M.Nataraj, A.S.G. Mr. Vatsal Joshi, Adv. Mr. Chitransh Sharma, Adv. Mr. Sharath Nambiar, Adv. Ms. Aashna Gill, Adv. Mr. Santosh Ramdurg, Adv. Mr. Yogesh Vats, Adv. Mr. Shreekant Neelappa Terdal, AOR
Table of Contents
2. Appellants argue that statutory deeming provisions for multi-state status are not automatic and require factual inquiry into objects, while some respondents contend deeming provisions apply by operation of law. (Para 10 , 11 , 12 )
3. The court found that deeming provisions are not automatic, necessitating proof that a society's principal objects—not merely the number of members—extend beyond a single state's boundaries. (Para 15 , 22 , 23 , 24 )
4. Deeming provisions for multi-state cooperative status cannot override completed reorganizations under state reorganisation acts when society objects remain confined to a single state. (Para 22 , 24 )
5. The court quashed the high court order, holding the societies are not multi-state, and directed officials to proceed with elections under state law. (Para 26 , 27 )
6. Is the status of a multi-state cooperative society under the 2002 Act automatic upon the reorganisation of a state?
No. The legal fiction of being a multi-state cooperative society is not automatic or universal. It is conditional upon a factual determination that the society's primary objectives legally extend beyond the borders of a single state, distinguishing between members' geographical residency and the society's defined functional objects. (Para 10 , 22 , 23 , 24 )
7. How do state reorganisation acts and the 2002 Multi-State Cooperative Societies Act interplay?
They must be interpreted harmoniously. The Reorganisation Act governs the administrative and legal consequences of state bifurcation, and its provisions can lawfully facilitate the reconstitution of societies before they transition into a multi-state classification, rendering the deeming provision under the 2002 Act inapplicable to such already reorganized entities. (Para 13 , 14 , 22 , 24 )
JUDGMENT :
ALOK ARADHE, J.
1. These batch of appeals raise an important question regarding legal status of two Sugarcane Cooperative Societies on bifurcation of erstwhile State of Uttar Pradesh and interplay between Uttar Pradesh Reorganisation Act, 2000 (Reorganisation Act) and Multi-State Cooperative Societies Act, 2002 (2002 Act). The core issue is whether Sugarcane Growers Cooperative Societies, Bajpur and Gadarpur, situated in Udham Singh Nagar, District of Uttarakhand could be treated as Multi-State Cooperative Societies by operation of Section 103 of 2002 Act, despite their prior reorganisation and confinement of their area of operations to a single State, under the statutory framework governing State reorganisation.
2. For the facility of reference, facts from C.A. No. 8743 of 2013 are being referred to. Sugarcane Growers Cooperative Society, Bajpur (Society) is a Sugarcane Growers Cooperative Society whose area of operation originally included 96 villages in Bajpur and 34 villages in Suar, District Rampur in the erstwhile State of Uttar Pradesh. The Society was registered under the U.P. Cooperative Societies Act, 1965 (1965 Act). The Registrar, Cane Cooperative Societies, Uttar Pradesh, on 10.07.1998 passed an order superseding the managing committee of the society. The District Cane Officer, Udham Singh Nagar assumed the charge of the society, as its administrator.
3. The Parliament enacted the Reorganisation Act, by which the State of Uttaranchal (‘now Uttarakhand’) was created with effect from 09.11.2000. On reorganisation of the State of Uttar Pradesh, 34 Revenue Villages, including village Suar, fell into the territory of the successor State of Uttar Pradesh and the villages of Tehsil Bajpur fell into the successor State of Uttaranchal. Thus, the area of operation of society spanned over the two states, namely State of U.P. and State of Uttarakhand.
4. A meeting between the officers of State of U.P. and Officers of State of Uttaranchal was convened on 08.02.2001, in which it was decided that in respect of the societies which have assumed the status of a multi-state cooperative society, a meeting of General Body shall be convened for reconstitution of such societies and with consent of both the States, the proposal shall be sent for their reorganization to the Central Registrar, Multi-State Cooperative Societies. Accordingly, a meeting of the General Body of the Society was convened on 03.04.2001 in which unanimously a resolution for reorganisation of the Society was passed. The Cane Commissioner/Registrar Cooperative Societies, Uttar Pradesh on 03.11.2001 made appropriate amendments in bye-law no. 3 of the Society.
5. The Deputy Cane Commissioner, Moradabad by an order dated 14.05.2002 directed deletion of names of 34 villages including the village Suar in District Rampur, from the area of operation of the society and ordered inclusion of the said villages in Sugarcane Cooperative Society Ltd. Suar, District Rampur, U.P. Consequently, the area of the operation of the society was curtailed and restricted to the areas which fell in the Territory of State of Uttaranchal.
6. The respondent No. 1’s name, who is a cane grower of village, Suar, was not included in the list of members of the society. He, therefore, filed a Writ Petition before the High Court, which was dismissed on 13.12.2002, on the ground that respondent No. 1 has an alternative remedy of arbitration before the Central Registrar under the 2002 Act. The respondent no. 1 thereupon initiated arbitration proceeding before the Central Registrar against his exclusion from membership of the society. The sole arbitrator by an award dated 31.08.2004, held that by virtue of Section 103 of 2002 Act, the society became a Multi-State Cooperative Society on 09.11.2000. It was further held that the meeting of the General Body of the Society dated 03.04.2001 and order dated 14.05.2002 passed by Deputy Cane Commissioner were illegal and void, and Respondent No. 1 continued
