Full Text
HIGH COURT OF DELHI
Date of Decision: 22.05.2026
SATYA PRAKASH RAVIDAS .....Appellant
Through: Appellant in person.
Through: Mr. Ashish K. Dixit, Mr. Adhiraj Singh, Mr. Umar Hashmi & Ms. Iqra Sheikh, Advs. for UOI.
Mr. Anil Dutt & Mr. Anupam Chaudhary, Advs. for R-8&9.
HON'BLE MR. JUSTICE TEJAS KARIA TEJAS KARIA, J. (Oral)
JUDGMENT
1. The present Letters Patent Appeal has been preferred against the order dated 20.04.2026 (“Impugned Order”) passed in W.P.(C) 18571/2025 (“Writ Petition”), titled Satya Prakash Ravidas v. Union of India & Ors.
2. The Appellant is aggrieved by the alleged irregularities in the management and affairs of Raj Vidya Kender (“RVK”), a society registered in Delhi under the Societies Registration Act, 1860 (“Act”).
3. The Appellant instituted the Writ Petition seeking directions in relation to the alleged mismanagement of the affairs of RVK. The learned Single Judge dismissed the Writ Petition, observing that the Appellant ought to have pursued his grievance before the competent Civil Court in accordance with the provisions of the Act.
4. The Appellant in person submitted that the learned Single Judge failed to distinguish between a private dispute concerning the internal management of a society and a public law challenge arising from the failure of statutory authorities to act upon official findings of illegality.
5. It was contended by the Appellant that the Writ Petition principally sought enforcement of statutory and public duties by the police authorities and the Registrar of Societies, matters which squarely fall within the ambit of writ jurisdiction.
6. The Appellant further submitted that the existence of fictitious identities within a registered society gives rise to serious public law consequences warranting judicial scrutiny. It was argued by the Appellant that the interstate functioning of a Delhi-registered society without statutory authorization raises issues of legality, public administration, and statutory compliance.
7. It was further contended by the Appellant that the learned Single Judge failed to appreciate that the Appellant had sought preventive and regulatory directions against continuing unlawful activities affecting the public at large, and that the existence of an alternative remedy does not constitute an absolute bar where public authorities fail to discharge their statutory duties.
8. Learned counsel appearing for Respondent No. 1 submitted that this Court, in Satya Prakash Ravidas v. Alakh Niranjan Prasad Singhna and Ors., Neutral Citation: 2026:DHC:837, has held that matters pertaining to the internal management of a society cannot be adjudicated by this Court in exercise of its jurisdiction under Article 226 of the Constitution of India,
1950.
9. It was further submitted by learned Counsel for Respondent No. 1 that the aforesaid judgment was upheld by this Court vide order dated 09.04.2026 passed in Satya Prakash Ravidas v. Registrar of Societies and Anr., LPA 240/2026.
10. We have heard the Appellant in person and learned Counsel for Respondent No. 1.
11. A bare perusal of the prayer clause in the Writ Petition reveals that the Appellant sought directions concerning the internal management of RVK, a registered society. It is well settled that disputes relating to the internal management of registered societies are not amenable to adjudication by this Court in exercise of its powers under Article 226 of the Constitution of India, 1950.
12. In view of the same, we are of the considered opinion that the learned Single Judge has taken the correct view by relegating the Appellant to the remedy of instituting a Civil Suit for redressal of grievances of the Appellant before the competent Civil Court. Accordingly, we do not find any merit in the present Appeal as the Appellant has failed to make out any ground warranting interference with the Impugned Order. Accordingly, the present appeal is hereby dismissed.
13. It is, however, clarified that all rights and contentions available to the Parties are left open to be urged before the competent Civil Court and the Parties are at liberty to raise any pleas that are available to them in accordance with law.
14. There shall be no order as to costs.
TEJAS KARIA, J [DEVENDRA KUMAR UPADHYAYA, CJ MAY 22, 2026/ AK