Civil jurisdiction over society election disputes and rendition of accounts remains available where the statutory bar is limited.

Section 23 of the Societies Registration Act, 1860, as applicable in Uttar Pradesh, was confined to audit of society accounts and did not bar a claim for rendition of accounts. Section 25 applied only to disputes concerning election or continuance in office of office-bearers before the prescribed authority, subject to its statutory conditions. A civil suit challenging the election of office-bearers and seeking rendition of accounts therefore remained within ordinary civil jurisdiction under Section 9 of the Code of Civil Procedure, 1908, and the special election-dispute procedure did not by itself exclude that remedy. The suit was maintainable and the statutory bar did not apply.

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Issues: Whether the civil suit challenging the election of office-bearers and seeking rendition of accounts was barred by Sections 23 and 25 of the Societies Registration Act, 1860, as applicable in Uttar Pradesh.

Analysis: Section 23 was confined to audit of society accounts and did not govern a claim for rendition of accounts. Section 25 dealt only with disputes regarding election or continuance in office of office-bearers before the prescribed authority, subject to the statutory conditions for a reference. The relief sought in the civil suit fell within the ordinary civil jurisdiction under Section 9 of the Code of Civil Procedure, 1908, and the existence of a special statutory procedure for election disputes did not by itself exclude a civil remedy for matters outside that limited field. The suit was therefore not hit by the statutory bar.

Conclusion: The suit was maintainable in the civil court and the bar under Section 25 did not apply.

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