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S.Ayyanar v. The Inspector General of Registration

Madras HC3 Jun 2026WP(MD)/7474/2026

Case brief

AI extract

What is this about?

Form VII; Registrar of Societies ministerial function; Tamil Nadu Societies Registration Act 1975 Section 14(1) Section 15; election dispute office-bearers bye-laws; cancellation of Form VII not maintainable before Registrar; no power to adjudicate election validity rival claims irregularities; remedy before civil court; mandamus under Article 226 refused; representation dated 10.11.2025; election dated 30.06.2025; Watrap Sivakasi Nadar Uravin Murai Sangam Dharma Paribalana Sangam; District Registrar Virudhunagar; W.P(MD)No.7474 of 2026; W.M.P(MD)No.6140 of 2026; Hemant Chandangoudar J.; Madurai Bench Madras High Court; disposed with liberty, no costs.

What did the court decide?

No mandamus direction issued; liberty reserved to the petitioner to approach the jurisdictional civil court for appropriate relief. ¶47

S.Ayyanar Vs The Inspector General of Registration — Writ and Judicial Review | Madras HC (2026)

What the court decided

AI extract

Outcome

No mandamus direction issued; liberty reserved to the petitioner to approach the jurisdictional civil court for appropriate relief.

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Issue for consideration

Whether a writ of mandamus can be issued directing the third respondent to consider and pass orders on the petitioner's representation dated 10.11.2025 and cancel the registration of the office-bearers of the Sangam effected on 30.06.2025. +2 more

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Court's answer

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; accordingly no direction can be issued by this Court as prayed for, and the writ petition is devoid of merit.

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Ratio / Principle

While dealing with Form VII, the Registrar of Societies performs only a ministerial function: he verifies whether the particulars furnished are in order and, if satisfied, accepts and records them; the scrutiny 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.

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Key takeaways

The Registrar is not vested with power to adjudicate disputes relating to the validity of elections, to determine whether an election was conducted in accordance with the bye-laws of the society, to examine rival claims to office, or to enquire into alleged irregularities in the election process; such disputed questions are beyond the scope of the Registrar's jurisdiction under the Act.ratio¶40
A complaint submitted to the Registrar seeking cancellation of Form VII on the ground that the election of the office-bearers was invalid is not maintainable before the Registrar.ratio¶41

Detailed headnote1 paragraphs

Madras High Court (Madurai Bench), Hemant Chandangoudar, J. — W.P(MD)No.7474 of 2026, decided 03.06.2026 (connected W.M.P(MD)No.6140 of 2026). A member of the Watrap Sivakasi Nadar Uravin Murai Sangam Dharma Paribalana Sangam sought a mandamus under Article 226 directing the District Registrar (Societies Registration), Virudhunagar to decide his representation dated 10.11.2025 and cancel the Form VII registration of T.Baskaran and other office-bearers elected on 30.06.2025, alleging the election violated the Sangam's bye-laws. HELD: Under Sections 14(1) and 15 of the Tamil Nadu Societies Registration Act, 1975, the Registrar, while dealing with Form VII, performs only a ministerial function confined to verifying the correctness of the particulars furnished; he has no power to adjudicate the validity of elections, bye-law compliance, rival claims to office, or election irregularities, such questions being beyond his jurisdiction under the Act. A complaint seeking cancellation of Form VII on the ground of an invalid election is therefore not maintainable before the Registrar; no statutory duty exists to consider such a representation, so no mandamus could issue. Writ petition disposed of with liberty to approach the jurisdictional civil court, any such proceedings to be decided on their own merits; no costs; connected miscellaneous petition closed.

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W.P(MD)No.7474 of 2026

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BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

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DATED: 03.06.2026

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CORAM

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THE HONOURABLE MR.JUSTICE HEMANT CHANDANGOUDAR

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Writ Petition(MD)No.7474 of 2026

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and

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W.M.P(MD)No.6140 of 2026

S.Ayyanar

.. Petitioner

1.The Inspecrtor General of Registration,

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Office of the Inspector General of Registration, No.100, Santhome High Road,

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Chennai - 600 028.

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2.The Deputy Inspector General of Registration, Office of the Deputy Inspector General of Registration, Vandikaran Street,

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Ramanathapuram - 623 501.

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3.The District Registrar (Societies Registration), Office of the District Registrar, Virudhunagar District, Virudhunagar.

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4.T.Baskaran

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..Respondents

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Prayer: Writ Petition filed under Article 226 of the Constitution of India, praying this Court to issue a Writ of Mandamus to direct the third respondent to consider and pass orders on the petitioner's representation dated 10.11.2025 and cancel the registration of the office bearers dated 30.06.2025.

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7474 of 2026

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For Petitioner : Mr.M.Ashok Kumar For Respondents : Mr.M.Mahaboob Athiff

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Govt. Advocate for R1 to R3

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ORDER

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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.

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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.

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7474 of 2026

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

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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.

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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.

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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

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7474 of 2026

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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.

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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.

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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.

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9.Since no statutory duty is cast upon the third respondent to adjudicate such election disputes or to consider the petitioner’s

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7474 of 2026

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representation in the manner sought, no direction can be issued by this Court as prayed for. The writ petition is therefore devoid of merit.

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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 proceedings are instituted, the same shall be considered and decided on their own merits and in accordance with law.

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11.There shall be no order as to costs. Consequently, the connected miscellaneous petition is closed.

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03.06.2026

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NCC : Yes/No Index : Yes/No Internet:Yes

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skn

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