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2026 Supreme(Online)(Mad) 47005

IN THE HIGH COURT OF JUDICATURE AT MADRAS
Hemant Chandangoudar, J
Ayyanar – Appellant
Versus
Inspector General Of Registration – Respondent
Writ Petition|W.M.P(MD)No.6140 of 2026



Advocates:
For the Appellants/Petitioners: Ashok Kumar
For the Respondents: Mahaboob Athiff

The Registrar of Societies performs a strictly ministerial function under the Tamil Nadu Societies Registration Act, 1975, and lacks the jurisdiction to adjudicate disputes concerning the validity of elections or internal affairs of a registered society, which must be resolved by a competent civil court.

Headnote:The petitioner filed a writ petition seeking a writ of mandamus to direct the Registrar to cancel the registration of office-bearers of a society, alleging irregularities in the election process. The court analyzed the Registrar's powers under the Tamil Nadu Societies Registration Act, 1975, specifically regarding the filing and acceptance of Form VII. It determined that the Registrar's function in relation to Form VII is purely ministerial and does not empower them to adjudicate election disputes or examine the legality of election procedures. The main issues addressed were whether the Registrar has jurisdiction to resolve election disputes within a registered society and whether the petitioner’s representation regarding election irregularities could be entertained by the Registrar. The court held that the Registrar lacks the power to determine the validity of elections or address rival claims to office, noting that these matters fall outside the statutory jurisdiction granted by the Act. It established that such disputes are within the exclusive domain of the civil courts. The writ petition was dismissed, holding it devoid of merit, with the court granting liberty to the petitioner to approach the appropriate civil court for resolution of the election dispute on its merits.

Table of Content
1. petitioner seeks cancellation of society election results via writ of mandamus. (Para 1 , 2)
2. registrar's function regarding form vii is ministerial, not adjudicatory. (Para 4 , 5 , 6 , 7 , 8)
3. election disputes must be resolved by the jurisdictional civil court. (Para 9 , 10 , 11)

ORDER

The petitioner has approached this Court seeking a direction to the third respondent to consider and pass orders on his representation dated 10.11.2025 and consequently cancel the registration of the office-bearers of the Sangam effected on

30.06.2025.

2.The petitioner claims to be a member of the Watrap Sivakasi Nadar Uravin Murai Sangam Dharma Paribalana Sangam. According to him, he, along with certain other members, submitted a complaint before the third respondent contending that the election/selection of the fourth respondent as President of the Sangam and the election of other office-bearers on 30.06.2025 were not conducted in accordance with the bye-laws of the Sangam. On that basis, the petitioner sought an enquiry into the matter and cancellation of Form VII recording the fourth respondent and the other elected office-bearers as the President and members of the committee. The grievance of the petitioner is that the said representation has not been considered till date.

3.Heard the learned counsel appearing for the petitioner and the learned counsel appearing for the respondents.

4.Section 15 of the Tamil Nadu Societies Registration Act, 1975 provides that every registered society shall have a committee consisting of not less than three members for the management of its affairs. The provision further requires every registered society to file before the Registrar a copy of the register maintained under Section 14(1) of the Act and to notify the Registrar from time to time regarding any change in the composition of the committee.

5.In the present case, the fourth respondent submitted the particulars relating to the office-bearers and members of the committee of the Sangam before the Registrar. Upon verification, the same were accepted and recorded, resulting in the filing and acceptance of Form VII in respect of the fourth respondent and the other office-bearers.

6.It is well settled by a catena of decisions of this Court that while dealing with Form VII, the Registrar of Societies performs only a ministerial function. The Registrar is required to verify whether the particulars furnished in the Form are in order and, upon being satisfied, accept and record the same. The scope of scrutiny undertaken by the Registrar is confined to the correctness of the particulars furnished and does not extend beyond the ministerial nature of the function entrusted to him under the Act.

7.The Registrar is not vested with the power to adjudicate disputes relating to the validity of elections, determine whether an election has been conducted in accordance with the bye-laws of the society, examine rival claims to office, or enquire into alleged irregularities in the election process. Such disputed questions are beyond the scope of the Registrar’s jurisdiction under the Act.

8.In view of the aforesaid legal position, the complaint submitted by the petitioner seeking cancellation of Form VII on the ground that the election of the office-bearers was invalid is not maintainable before the Registrar. The appropriate remedy available to the petitioner is to approach the competent civil court for adjudication of the disputes relating to the validity of the election and the consequential entries made in Form VII.

9.Since no statutory duty is cast upon the third respondent to adjudicate such election disputes or to consider the petitioner’s representation in the manner sought, no direction can be issued by this Court as prayed for. The writ petition is therefore devoid of merit.

10.Accordingly, the writ petition stands disposed of, reserving liberty to the petitioner to approach the jurisdictional civil court for appropriate relief. If any such proceedin

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