Registrar of Societies lacks implied power to decide validity of rule amendments or annul them under the registration statute.

The Societies Registration Act, 1860 does not confer a general power on the Registrar of Societies to adjudicate disputes over amendments to a society's rules and regulations or to declare such amendments void and non est. The statutory scheme permits registration, filing of memorandum and rules, and limited functions such as change of name, but it does not authorise scrutiny of alleged irregularities in the society's internal amendment . Section 21 of the General Clauses Act, 1897 cannot be used to imply such adjudicatory authority. Disputes about the validity of the amendments are instead to be examined in civil proceedings.

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Issues: Whether the Registrar of Societies had jurisdiction or statutory authority under the Societies Registration Act, 1860 to adjudicate disputes concerning amendments to a society's rules and regulations, or to declare such amendments void and non est.

Analysis: The provisions governing registration of societies and changes in name or objects do not confer any general adjudicatory power on the Registrar to decide disputes about the validity of amendments to rules and regulations. The statutory scheme permits registration of a society, filing of its memorandum and rules, and in Delhi, specific powers relating to change of name, but it does not authorise the Registrar to examine alleged irregularities in the internal procedure adopted by the society for amending its rules. Section 21 of the General Clauses Act, 1897 could not be invoked to supply such a power. Any dispute concerning the validity of the amendments was already the subject of civil proceedings and could be examined there.

Conclusion: The Registrar lacked jurisdiction to pass the impugned order; the order was unsustainable and liable to be set aside.

Ratio Decidendi: A statutory authority cannot assume adjudicatory or cancellation powers that are not expressly conferred by the governing statute, and such powers cannot be implied merely from the power to register or certify.

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