Statutory enquiry and natural justice are mandatory before appointing an administrator over a society's management.

A valid enquiry into a society's affairs under Section 25 required a compliant complaint or a lawful suo motu process by the Registrar, followed by notice and enquiry; a complaint that did not meet those statutory preconditions was invalid. The Registrar's report was unlawful because no notice was issued to the society or its executive committee and no proper enquiry was conducted, contrary to Section 25, Rule 8 and natural justice. An administrator could not be appointed under Section 27A(1)(c) on the basis of such a defective report, so the supersession order and consequential extensions were unsustainable and liable to be quashed.

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Issues: (i) Whether the complaint made by the fifth respondent with other persons satisfied the requirements of Section 25 for a valid enquiry into the affairs of the society. (ii) Whether the Registrar's report was prepared after the enquiry required by Section 25 and Rule 8 and in compliance with natural justice. (iii) Whether the Government's order appointing an administrator under Section 27A(1)(c) was valid and legal.

Issue (i): Whether the complaint made by the fifth respondent with other persons satisfied the requirements of Section 25 for a valid enquiry into the affairs of the society.

Analysis: The complaint was not made in the manner contemplated by Section 25. The statutory scheme required a proper complaint by the requisite persons or a suo motu enquiry by the Registrar, followed by notice and enquiry. On the record, the complaint did not meet the mandatory preconditions for initiating the process against the society.

Conclusion: The complaint was not a valid complaint under Section 25.

Issue (ii): Whether the Registrar's report was prepared after the enquiry required by Section 25 and Rule 8 and in compliance with natural justice.

Analysis: The records showed that no notice was issued to the society or its executive committee and no proper enquiry was conducted before the report was submitted. Since the report could lead to serious civil consequences, compliance with the statutory procedure and a fair opportunity of hearing was essential. The report was therefore made without following the mandatory procedure and without observing natural justice.

Conclusion: The Registrar's report was not lawful and was not preceded by the required enquiry or observance of natural justice.

Issue (iii): Whether the Government's order appointing an administrator under Section 27A(1)(c) was valid and legal.

Analysis: The Government acted by accepting the defective report without independently satisfying itself that the statutory requirements had been followed. As the foundation report itself was invalid and the affected society was not heard, the order superseding the committee and appointing an administrator could not stand. The subsequent extensions and acts flowing from that order were equally unsustainable.

Conclusion: The order appointing the administrator was illegal and liable to be quashed.

Final Conclusion: The writ petition succeeded, the impugned administrative actions were set aside, and the society was directed to be managed by the existing committee until fresh elections were held in accordance with law.

Ratio Decidendi: An administrator cannot be appointed under Section 27A(1)(c) on the basis of a report that is not preceded by the enquiry and notice required by Section 25 and Rule 8, because compliance with the statutory procedure and natural justice is mandatory where serious civil consequences follow.

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