1. Application seeking permission to conduct Ramlila on society land during ongoing litigation; allegations of concealment. (Para 3 , 4 , 5 )
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2026 Supreme(Online)(Del) 17998
IN THE HIGH COURT OF DELHI AT NEW DELHI
Prathiba M. Singh, Dinesh Bhatt, JJ
Reetu Mongia – Appellant
Versus
Government of NCT of Delhi – Respondent
W.P.(C) 13390/2026 | CM APPL. 64686/2026 | CM APPL. 64687/2026
Advocates:
For the Appellants/Petitioners: Rakesh Patiyal, Surender Nagpal, Rohan Nagpal, Nikita Nagpal
For the Respondents: N. Hariharan, Rakesh Patiyal, Surender Nagpal, Sanjiv Sharma, Punya Rekha Angara, Amartya, Aman Akhtar, Vasundhara Raj Tyagi, Arjan Singh Mandla, Apoorv Kumar, Rohan Nagpal, Nikita Nagpal, Deeksha L. Kakar, Sana Parveen, Kajal, Vinay Kaushik, Manu Chaturvedi, Anubhav Gupta, Shashi Pratap Singh, Abhinav Sharma, Tushar Sannu
For the Appellants/Petitioners: Rakesh Patiyal, Surender Nagpal, Rohan Nagpal, Nikita Nagpal
For the Respondents: N. Hariharan, Rakesh Patiyal, Surender Nagpal, Sanjiv Sharma, Punya Rekha Angara, Amartya, Aman Akhtar, Vasundhara Raj Tyagi, Arjan Singh Mandla, Apoorv Kumar, Rohan Nagpal, Nikita Nagpal, Deeksha L. Kakar, Sana Parveen, Kajal, Vinay Kaushik, Manu Chaturvedi, Anubhav Gupta, Shashi Pratap Singh, Abhinav Sharma, Tushar Sannu
The court held that concealment of material facts by a court-appointed administrator constitutes misrepresentative conduct, justifying the administrator's removal and the appointment of a successor to ensure transparency and legal compliance.
Headnote:(A) Misrepresentation to Court - Concealment of Material Facts - An Administrator's failure to disclose the receipt of an application and payment for land use, while claiming to the Court that no permission was granted, constitutes misrepresentative conduct. (Para 11, 12)
(B) Administration of Cooperative Societies - Removal of Administrator - Where an administrator is found to have misled the court, the court may direct the appointment of a new administrator to ensure proper governance and compliance with judicial orders. (Para 13)
Issues: Whether the application for conducting Ramlila should be permitted and whether the conduct of the Society's Administrator warranted his removal.
Legal Category Hierarchy
- practice and procedure
- property law
Table of Contents
2. Applicant claimed permission granted by Administrator; Administrator denied granting any permission for the event. (Para 5 , 6 , 7 )
3. Court found Administrator concealed receipt of application and payment; misrepresentative conduct recorded. (Para 10 , 11 , 12 )
4. Non-disclosure of material facts by Administrator to court amounts to misrepresentative conduct warranting replacement. (Para 11 , 12 , 13 )
5. Applicant permitted to conduct Ramlila; Administrator replaced; records to be handed over to new appointee. (Para 13 , 14 , 16 , 17 )
6. What constitutes misrepresentative conduct by an administrator before a court?
Concealing receipt of an application and payment for conducting an event, when denying permission for any event on the land, amounts to misrepresentative conduct. (Para 11 , 12 )
7. Can a party be permitted to conduct an event despite an earlier order restraining events on the land?
Yes, if the facts were concealed from the court and the applicant has been conducting the event for several years, the court may permit the event and modify its earlier order. (Para 13 )
8. What directions may a court issue for non-disclosure of material facts by an administrator during ongoing litigation?
The court may direct the appointing authority to appoint a new administrator, order handover of records, and restrain the previous administrator from visiting the society's office. (Para 13 )
1. This hearing has been done through hybrid mode.
CM APPL. 64687/2026 (for exemption)
2. Allowed, subject to all just exceptions. Application is disposed of.
CM APPL. 64686/2026
3. The present application has been filed by Respondent No. 7 – Nav Shree Manav Dharm Ramlila Committee (hereinafter ‘Ramlila Committee’) through its office bearer Mr. Vikesh Sethi, the President, inter alia, seeking permission to conduct Shri Ramlila Manch from 11th October, 2026 to 21st October, 2026.
4. The case of the Applicant is that it has been conducting Ramlila on the vacant land of Dera Ismail Khan House Building Cooperative Society Ltd.(hereinafter ‘the Society’) since 2019.
5. Mr. Hariharan, ld. Senior Counsel for the Applicant submits that the Applicant had applied to the Administrator of the Society i.e., Mr. V.K. Rastogi on 20th August, 2026 and had also paid a sum of Rs.1,50,000/- by means of a cheque payment seeking permission to hold the Ramlila on the land of the Society. It is his further submission that the said application has been duly acknowledged by the Administrator and the cheque has also been encashed. Inviewthereof, the Bhumi Poojan for conducting the Ramlila from 11th October, 2026 to 21st October, 2026 was also conducted on 30th August, 2026.
6. Mr. Hariharan, ld. Senior Counsel further submits that when the order dated 14th September, 2026 was passed by this Court, these facts do not appear to have been brought to the notice of the Court.
7. The Court has questioned the Administrator who is present in Court, whose only stand is that he did not grant any permission for the Ramlila. However, on a query from the Court as to why the application filed by the Respondent No.7 was not disclosed on 14th September, 2026, he is unable to give a satisfactory answer.
8. The Administrator-Mr. Rastogi has today handed across a letter dated 21st August, 2026 stated to have been delivered on 25th August, 2026 in the office of the Registrar of Cooperative Societies (hereinafter ‘RCS’), wherein he seeks permission from the RCS to empower him to grant permission for running of the Ramlila.
9. This Court has also heard Mr. Shashi Pratap Singh, ld. Counsel for the RCS in the connected matter i.e., W.P.(C) 11548/2024 titled ‘Gopi Chand Bhatia & Ors. v. Registrar of Delhi Cooperative Societies & Ors.’, who is requested to accept notice in this application on behalf of Ms. Nikita Bhutani, ld. Counsel.
10. After hearing ld. Counsels for the parties and Mr. Rastogi, the Court clearly is of the opinion that these facts were not brought to the notice of the Court on 14th September, 2026 when the order was passed. On 14th September, 2026, it was specifically recorded that neither the trustees of Amardev Trust nor the Administrator had given any permission to hold any event on this land. The relevant portions of the said order is set out below:
“8. The Court has heard the ld. Counsels for the parties. As per Mr. Sharma, ld. Senior Counsel, the stand of the SADE Trust is that by way of a Trust Deed dated 14th February, 1986 the Society had vested in the Trust a parcel of land admeasuring 7.70 acres, out of which 4.17 acres was to be used for setting up of a school. It is on this basis that the SADE Trust claims rights in the 7.70 acres of land.
9. The Petitioners and the Administrator dispute this position. Reliance is placed by Mr. Panda, ld. Sr. Counsel upon various orders passed by this Court including order dated 16th August, 1983, 23rd September, 1983 and 28th September, 1983 in W.P.(C) 1777/1983.
10. It is further submitted on behalf of the Petitioners that the land is being misused by the SADE Trust and its trustees and recently some bhoomi poojan was also conducted. In respect of the same, reliance is placed on certain photographs that have been handed over by Mr. Panda, ld. Sr. Counsel. As of today, certain pandals are also being erected on the subject land.
11. Mr. Kundan Chitkara, one of the trustees, submits that the SADE Trust has not
