Registrar jurisdiction under co-operative societies law is confined to specified dispute classes, not all society-versus-non-member claims.

Section 48 of the Bihar and Orissa Co-operative Societies Act, 1935 created a special forum only for specified categories of disputes touching a registered society's business, mainly disputes among members and certain limited disputes involving financing banks or non-members under Section 16(1). The Explanation did not expand that jurisdiction to every society-versus-non-member claim, even where a debt or demand was admitted and only payment terms were disputed. As the dispute over commission and interest for sugarcane supply did not fall within the statutory classes, the Registrar lacked jurisdiction and the matter had to be pursued in the ordinary courts.

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Issues: Whether a dispute between a registered co-operative society and a non-member, arising out of a claim for commission and interest for supply of sugarcane, fell within the jurisdiction of the Registrar under Section 48 of the Bihar and Orissa Co-operative Societies Act, 1935, as amended.

Analysis: Section 48 created a special tribunal for disputes touching the business of a registered society, but its clauses were directed to specified classes of disputes, principally among members, past members, persons claiming through them, sureties, and certain disputes involving financing banks and non-members under Section 16(1). The Explanation to Section 48 clarified that a claim for debt or demand could remain a dispute even if admitted and only payment terms were in issue, but it did not enlarge the main provision so as to bring every dispute between a society and a non-member within the Registrar's cognizance. The amendment introducing the word non-member in the Explanation did not convert the section into a general jurisdictional provision for all society-versus-non-member disputes. Since the respondent was not a financing bank and the appellant was not an agriculturist receiving advances under Section 16(1), the dispute did not fall within the statutory categories.

Conclusion: The Registrar had no jurisdiction to entertain or adjudicate the reference, and the dispute was left to be pursued in the ordinary courts; the appeal succeeded.

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