THE SUGAULI SUGAR WORKS (PRIVATE) LTD. vs THE ASSTT. REGISTRAR, CO-OPERATIVESOCIETIES

The Supreme Court ruled that the Registrar of Co-operative Societies under the Bihar and Orissa Co-operative Societies Act, 1935, as amended by the Bihar Co-operative Societies (Amendment) Act, 1948, lacks jurisdiction under Section 48(1) to entertain claims made by a registered society against a non-member. The Court clarified that the addition of 'non-member' in the 1948 amendment does not expand the Registrar's authority to all disputes involving non-members. Consequently, the previous ruling in Union of India v. Registrar, Co-operative Societies, Patna was overruled, affirming that only specific claims by financing banks against non-members are cognizable under Section 48(1).