Voluntary association rights include chosen membership; compulsory outsider induction and property deprivation made the Act unconstitutional.

A law that compulsorily introduced outsiders into a voluntary association was held to infringe the founders' Article 19(1)(c) right to form and continue the association with its chosen membership. The measure was not saved by Article 19(4). An alternative reading, under which the original society survived while a new statutory body took over its property and functions, also failed because it raised legislative competence concerns and amounted to total deprivation of property rather than a reasonable restriction. The Act was held unconstitutional in its entirety, with consequential relief and restraint against action under it.

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Issues: (i) Whether the impugned Act, by altering the composition and membership of the voluntary association, infringed the right to form an association under Article 19(1)(c) of the Constitution of India. (ii) Whether the Act could nevertheless be sustained as a reasonable restriction or on the alternative footing that the original society continued to exist while a new statutory body was created, including on the aspect of property and legislative competence.

Issue (i): Whether the impugned Act, by altering the composition and membership of the voluntary association, infringed the right to form an association under Article 19(1)(c) of the Constitution of India.

Analysis: The statutory scheme did not merely regulate the internal management of an existing body. It introduced members into the association without the choice or consent of the original members and conferred power to continue enlarging membership through rules framed by a governmental body. The right to form an association was held to include the right to continue the association with the composition voluntarily agreed upon by its founders. Compulsory introduction of outsiders into a voluntary association was treated as interference with that protected right.

Conclusion: The Act violated Article 19(1)(c) and was not protected by Article 19(4). The impugned provisions were unconstitutional.

Issue (ii): Whether the Act could nevertheless be sustained as a reasonable restriction or on the alternative footing that the original society continued to exist while a new statutory body was created, including on the aspect of property and legislative competence.

Analysis: The alternative construction could not save the Act. On that reading, Parliament would have transferred the property and functions of the original society to a distinct body that had never itself been declared an institution of national importance, creating a serious difficulty of legislative competence. Further, if the original society continued to exist, deprivation of its property and of the property vested in its governing body could not be treated as a reasonable restriction in the public interest. The statutory interference went beyond regulation and amounted to total deprivation.

Conclusion: The alternative basis also failed, and the Act could not be upheld as valid.

Final Conclusion: The judgment invalidated the Act in its entirety and granted relief to the challengers, with consequential restraint against action under the Act.

Ratio Decidendi: The constitutional right to form an association includes the right to continue that association with its voluntary composition, and a law that compulsorily alters membership or deprives the association of its property without constitutional justification is invalid.

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