Disputes arising from the internal management of a registered society are not justiciable in writ jurisdiction and must be resolved in a competent civil court.

JUDGMENT :

SACHIN DATTA, J.

W.P.(C) 13723/2025, W.P.(C) 15987/2025, W.P.(C) 16305/2025 and W.P.(C) 2902/2025

1. Multiple writ petitions have been filed by the petitioner concerning the same society, i.e., Raj Vidya Kender (RVK). Having regard to the overlapping nature of the causes of action and the commonality of issues raised, it is considered appropriate to adjudicate all these petitions together.

2. The petitioner has approached this Court asserting his association with the affairs of RVK, a society registered under the Societies Registration Act, 1860, and formerly known as the Divine United Organisation (DUO). The petitioner has invoked the writ jurisdiction of this Court aggrieved with the current management and functioning of the society. According to the petitioner, there exists an alleged error in the bylaws of RVK, whereby the name of a fictitious individual, “Param Hans Sad Guru Dev Sri Sant Ji Maharaj,” has been inserted in place of the real and living individual, Mr. Prem Rawat.

3. It is further submitted that paragraph 3(a) of the bylaws of RVK describes the principal objective of the society as the propagation of the knowledge of “Param Hans Sadgurudev Shri Sant Ji Maharaj,” who, according to the petitioner, is a non-existent person. This alleged error has, in the petitioner’s view, enabled unelected individuals to seize control of the society and exploit it for their personal benefit.

4. The petitioner additionally contends that sub-paragraph 4(d) has been misused to suppress dissent and to insulate alleged offenders from accountability. He claims that key positions within RVK have been usurped by shareholders and employees of certain private entities, including those associated with one Mr. Deepak Raj Bhandari. It is contended that Mr. Deepak Raj Bhandari, a Nepalese national, who exercises unlawful control over RVK has committed a financial fraud of Rs.550.30 crores in relation to RVK.

5. It is also the petitioner’s allegation that the purported unelected governing body of RVK fabricated an authorization letter dated 16.04.2019 to initiate false litigation (CS (OS) 470/2019) against him. He further highlights that no balance sheets, election records, or statutory filings of RVK have been submitted before the Registrar of Societies since 2003.

6. The case of the petitioner is that RVK has remained a defunct society since 2003, with no lawful elections to its governing body for more than twenty-two years. The petitioner seeks to fasten admission/s by the Registrar of Societies, on the basis of certain communications, dated 20.11.2023, 27.09.2023, and 27.05.2024. It is emphasised that the Registrar has the authority to directly intervene and conduct an election for a society if the existing election process is deemed invalid or improperly conducted. It is submitted that the Registrar is vested with powers under Sections 12 , 12A, 13, 14, and 19 of the Act to regulate, call for information, and conduct enquiries into the affairs of societies.

7. It is submitted that the prolonged absence of elections and functioning governance renders all subsequent activities of RVK void and illegal. It is pointed that the unelected and unauthorized persons of RVK, have unlawfully sold the Ashram “Prem Bhawan Raj Vidya Kendra, Near Gaya Gumti, Patna. It is pointed that from 1987 onwards, the respondents, in collusion with private individuals are transferring and vest