Trade union election disputes cannot be adjudicated by the Registrar under Section 28(4); writ relief was found not maintainable.

A writ petition seeking a direction to the Registrar of Trade Unions to decide an intra-union election dispute was not maintainable because the relief directly affected rival claimants who were not impleaded, offending audi alteram partem. Section 28(4) of the Trade Unions Act, 1926 was held to confer only an administrative power to inspect and examine documents connected with statutory returns; it did not authorise adjudication of election disputes or rival claims to union office. Such contested disputes were treated as matters for a civil forum, not for indirect resolution through writ proceedings.

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Issues: Whether the writ petition seeking a direction to the Registrar of Trade Unions to resolve an intra-union election dispute was maintainable, and whether Section 28(4) of the Trade Unions Act, 1926 empowered the Registrar to adjudicate such dispute.

Analysis: The dispute was between rival groups claiming control over the same union, and the reliefs sought directly affected the rights of the rival group, which was not impleaded. On that basis, the petition offended the principle of audi alteram partem and was not maintainable against non-parties. The Court further held that Section 28 of the Trade Unions Act, 1926 deals only with returns and the Registrar's power under Section 28(4) is limited to inspection and examination of documents in connection with the statutory returns. That power is administrative in nature and does not extend to adjudication of election disputes or rival claims to union office. Such disputes, if contested, lie in a civil forum and not in writ proceedings seeking indirect settlement through representation.

Conclusion: The Registrar had no jurisdiction under Section 28(4) of the Trade Unions Act, 1926 to decide the intra-union election dispute, and the writ petition was not maintainable.

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