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2026 Supreme(Online)(Mad) 49887

IN THE HIGH COURT OF JUDICATURE AT MADRAS
P.Velmurugan, K.Govindarajan Thilakavadi, JJ
C.Chockalingam – Appellant
Versus
M.A.M.R Muthiah – Respondent
O.S.A.Nos.93, 95 and 96 of 2026|O.S.A.Nos.94, 97 and 98 of 2026|O.S.A.Nos.88, 89 and 90 of 2026



Advocates:
For the Appellants/Petitioners: M.Sricharan Rangarajan, RM.Arun Swaminathan, Krishna Srinivasan, Vadiraj Anirudh S.G, R.Srinivas, S.Adaikkappan @ Sithiraianandam
For the Respondents: M.S. Krishnan, T. Balaji, V. Raghavachari, M. Praveen Kumar, A.K. Sriram, R.I. Ramesh, Nithyaesh Natraj, Vaibhav R. Venkatesh, K.V. Babu, K.T. Shankar Subramanian, J. Ravindran, R. Srinivas, S. Adaikkappan, S.P. Arthi, AR.L. Sundaresan, S. Meenakshi

Interim relief and appointment of an administrator in Society management disputes must be based on complete pleadings and afford natural justice, and should not be granted if it effectively decides the core issues of the suit at an interlocutory stage without proper adjudication.

Headnote:The dispute concerns the internal administration of a Society registered under the Tamil Nadu Societies Registration Act, 1975, and its governing Bye-laws. Aggrieved by the exclusion of members and management changes, the plaintiffs initiated civil proceedings. The High Court analyzed the challenge to the Single Judge's order, which had granted sweeping interim injunctions and appointed an interim administrator upon interlocutory applications without allowing for formal counter-affidavits or detailed pleadings. The Court framed the issues around whether the interlocutory order violated natural justice, whether the relief granted exceeded the scope of the original prayers, and whether the plaintiffs had sufficient locus standi to interfere with the Managing Committee’s internal functions. The Court held that vital disputes regarding Society administration and interpretation of Bye-laws should not be resolved summarily at an interlocutory stage without providing sufficient opportunity for all parties to present their records. The Court set aside the impugned order, remitted the matter for fresh consideration by the Single Judge, and directed that the proposed meeting remain deferred pending the disposal of the applications.

Table of Content
1. overview of the background facts and the impugned order. (Para 1 , 2 , 3)
2. contentions regarding the lack of jurisdiction and violation of natural justice. (Para 4 , 5 , 6 , 7)
3. court's reasoning for setting aside the order to ensure fair hearing. (Para 8 , 9 , 10 , 11)

C O M M O N J U D G M E N T

(Judgment of the Court was delivered by P.VELMURUGAN, J.

1.These intra-Court Appeals are directed against the common order dated14.05.2026 rendered by the learned Single Judge in O.A.Nos.455 and 456 of 2026 and A.No.2130 of 2026 in C.S.No.54 of 2024. Under the impugned common order, the learned Single Judge restrained defendants 9 to 43 from convening the proposed Managing Committee Meeting scheduled to be held on 15.05.2026; restrained defendants 9 and 21 from interfering with the management, administration and financial affairs of the Society and School; and appointed Mr.P.Vijaykumar Reddy as interim Administrator of the Society, until further orders.

2. For the sake of convenience and clarity, the parties are referred to as per their ranking in C.S.No.54 of 2024.

3. The brief facts of the case are as follows :

3.1. The first defendant Society is registered under the provisions of Tamil Nadu Societies Registration Act, 1975, and administers and runs the School – Kumararani Meena Muthiah’s Chettinad Vidyashram. The said School was established in the year 1986 with the object of imparting quality education and promoting holistic development of its students. Over the years, the said institution has earned considerable goodwill. The management, affairs, and administration of the School are vested in the first defendant Society, which is governed in accordance with its registered Bye-laws through a duly constituted Managing Committee. The Bye-laws prescribe the following provisions for the effective functioning of the Society and its Managing Committee :

a) As per Bye Law 10, the power is vested with the Managing Committee to admit any person to be a member of the Society.

b) As per Bye Law 11, the Managing Committee shall have power to remove any member of the Society as it thinks fit, and no appeal shall lie against such removal.

c) As per Bye Law 14, the Managing Committee shall have at least 5 members and not more than 10 members.

d) As per Bye Law 15, the members of the Managing Committee shall be elected by the General Body and they shall hold office for a period of 3 years from the date of election.

e) As per Bye Law 16, irrespective of any vacancy, the Managing Committee shall function as a full committee.

f) As per Bye Law 17, the funds of the Society shall be vested with the Managing Committee, who shall have absolute power to administer the funds for promoting the objectives of the Society.

g) As per Bye Law 22, a Managing Committee meeting can be convened as and when necessary and in any case upon requisition by 2 members.

h) As per Bye Law 24, the accounts of the Society shall be administered by the Secretary and Treasurer who shall be responsible for maintenance and administration of the transactions and disbursements.

3.2. It is submitted that certain disputes had arisen within the first defendant Society concerning the removal of the plaintiffs from their membership in the Society and the induction of defendants 9 to 43. Consequently, Form VII was filed by the Managing Committee in accordance with the provisions governing the registration of societies under the Act. Aggrieved by their purported removal and the inclusion of new members, the plaintiffs preferred a complaint dated 17.12.2018 before the Registrar of Societies. The said complaint was adjudicated in detail by the fourth defendant, wherein three core issues arose for consideration in Proceedings No.1838/D2/2018. Firstly, whether the alleged removal of the plaintiffs from the Society was legally valid; secondly, whether the allegations concerning financial irregularities and misappropriation of funds by the Secretary, Mrs.Meena Muthiah, were sustainable; a

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