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2026 Supreme(Online)(Del) 813

IN THE HIGH COURT OF DELHI AT NEW DELHI
Purushaindra Kumar Kaurav, J
Sylom Blind Centre – Appellant
Versus
Union Of India – Respondent
W.P.(C) 277/2026



Advocates:
For the Appellants/Petitioners: Ujjwal Bhardwaj, Ravi Kumar
For the Respondents: Mukul Singh, Adhiraj Singh, Nandini Aggarwal

When a statutory body has not yet ruled on a party's pending representation regarding administrative findings, the court may direct the authority to consider the submission within a fixed timeline rather than adjudicating the merits of the underlying dispute itself.

Headnote:The case involves a challenge to the cessation of a registration certificate under the Foreign Contribution (Regulation) Act, 2010 (FCRA, 2010). The petitioner, a charitable organization, sought relief following the cessation of its registration certificate due to audit findings. The court observed that the petitioner had submitted a reply to the audit findings and required the competent authority to evaluate the pending representations. The court determined that the administrative authority must consider the petitioner's responses to ensure procedural fairness under the mandate of the Act. The central issue is whether the competent authority should reconsider the status of the registration after the submission of replies by the petitioner. The ratio decidendi established that judicial intervention is premature when an administrative body is yet to adjudicate upon a representation submitted by an aggrieved party, emphasizing the duty of the regulator to provide a reasoned decision on submitted responses. The writ petition is disposed of with directions for the Competent Authority to consider the petitioner's representations and render its decision within four months.

Table of Content
1. factual overview of the registration cessation and audit correspondence. (Para 1 , 2 , 3 , 4)
2. court directs administrative authority to decide upon pending representations. (Para 5 , 6 , 7)

O R D E R

CM APPL. 1223-1224/2026 (for exemption)

1. Exemption allowed, subject to all just exceptions.

2. The application stands disposed of.

W.P.(C) 277/2026

1. The petitioner claims to be a charitable and non-profitable organization registered under the Foreign Contribution (Regulation) Act, 2010 (“FCRA, 2010”). It appears that the inspection audit for the financial years 2015-16 and 2017-18 was conducted and pursuant to the audit observations, the petitioner’s registration certificate has been declared to be ceased.

2. The aforesaid position is noticeable in Annexure P-3, which states as under:-

“Registration Certificate is deemed to have ceased! (Association's FCRA certificate of registration has expired on 28/06/2024. No Association whose certificate of registration has ceased to exist shall either receive or utilise the foreign contribution until the certificate is renewed.)”

3. The record would indicate that, thereafter, the petitioner made a representation dated 03.06.2023 explaining its position. It also appears from the documents placed on record that on 03.11.2025, the concerned Ministry has sent a reminder to the petitioner regarding non-submission of its reply to the audit/inspection findings pursuant to the audit conducted under Sections 20 and 23 of the FCRA, 2010.

4. Learned counsel appearing on behalf of the petitioner points out that the reply to the letter dated 03.11.2025 had been furnished on 22.11.2025.

5. It is thus seen that the issue as to whether the petitioner’s account will have to be revoked/defreezed, will have to be taken by the concerned Ministry.

6. Under these circumstances, instead of entertaining the instant writ petition, the Court deems it appropriate to issue following directions:

(i) Let the petitioner’s reply dated 03.06.2023 and 03.11.2025 be considered by the Competent Authority and the decision be taken with respect to the entitlement or otherwise of the petitioner under FCRA, 2010 with due intimation to the petitioner;

(ii) The said decision be taken within a period of four months from the date of receipt of a copy of this order; and

(iii) Thereafter, the petitioner shall be at liberty to take appropriate recourse in accordance with law.

7. With the aforesaid directions, the instant writ petition stands disposed of.

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