Vested right to revision survives conversion into a multi-State cooperative society where no law takes away pending proceedings.

A vested right to seek revision against an adverse order arises when the original proceeding is instituted, and that right is ordinarily governed by the law then in force. Applying that principle, the Court held that conversion of a society into a multi-State cooperative society did not, by itself, extinguish a pending revision under the Maharashtra Cooperative Societies Act, 1960. In the absence of any express provision or necessary implication in either the Maharashtra Act or the Multi-State Cooperative Societies Act, 2002, pending revision proceedings remained maintainable and were not transferred to the forum under the later Act. The revisionary authority therefore retained jurisdiction to decide the revision on merits.

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Issues: Whether a revision application under Section 154 of the Maharashtra Cooperative Societies Act, 1960 remained maintainable after the society was converted into a multi-State cooperative society during the pendency of the revision.

Analysis: The right to challenge an adverse order is a vested right that accrues when the original proceeding is instituted and is ordinarily governed by the law then in force. The Court extended that principle to revision proceedings, holding that a revision, like an appeal, is a statutory remedy by which an aggrieved party seeks scrutiny of an order passed by a subordinate authority. Neither the Maharashtra Cooperative Societies Act, 1960 nor the Multi-State Cooperative Societies Act, 2002 contained any express provision or necessary implication extinguishing pending revision proceedings upon conversion of a society into a multi-State cooperative society. There was also no provision transferring pending matters to the forum under the Multi-State Act. The provisions dealing with appeals, revision, disputes and limitation under the Multi-State Act were held inapplicable to a revision already instituted under the Maharashtra Act.

Conclusion: The revisionary authority retained jurisdiction to decide the pending revision on merits, and the objection based on conversion into a multi-State cooperative society was rejected.

Final Conclusion: The impugned order was set aside and the revision was restored for decision on merits.

Ratio Decidendi: A statutory right to seek revision against an adverse order vests when the original proceeding is instituted, and that vested right is not displaced by a later change in the legal status of the party unless the later enactment expressly or by necessary intendment takes it away.

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