Supervisory powers over public trusts support locus standi to appeal against adverse decisions affecting charitable interests.

Under the Bombay Public Trusts Act, 1950, the Charity Commissioner's role was treated as supervisory and protective, not merely adjudicatory. The Act's powers of inspection, audit, surcharge, institution of breach-of-trust suits, and control over public trust administration, together with the notice-and-impleading scheme in Section 56-B, supported a purposive reading of the appellate framework. On that basis, the appellate remedy under Section 72 was not to be read narrowly so as to exclude the Charity Commissioner, and the Commissioner was entitled to appeal as of right against an adverse District Court decision affecting a public charity.

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Issues: Whether the Charity Commissioner had locus standi to appeal against the decision of the District Court under the Bombay Public Trusts Act, 1950.

Analysis: The statutory scheme showed that the Charity Commissioner was not confined to a purely adjudicatory role. The Act conferred powers of supervision, inspection, audit, surcharge, institution of suits in cases of breach of trust, and control over administration of public trusts. The notice-and-impleading mechanism in Section 56-B further indicated that the Charity Commissioner was intended to protect public religious and charitable interests in litigation affecting such trusts. Reading the Act purposively, the appellate remedy under Section 72 could not be construed narrowly so as to deny the Charity Commissioner the right to challenge an adverse decision affecting a public trust.

Conclusion: The Charity Commissioner was held entitled, as of right, to appeal against an adverse decision of the District Court affecting a public charity.

Ratio Decidendi: Where a statute vests a supervisory authority with control, inspection, audit, and protective functions over public trusts, the authority has locus standi to appeal against an adverse decision affecting the trust even without an express appellate provision in its favour.

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