NAGRI PRACHARINI SABHA AND ANR. vs VTH ADDl. DISTT. AND SESSIONS JUDGE, VARANASIAND ORS.

The Supreme Court held that a civil suit challenging the election of office bearers of a society and seeking rendition of accounts is maintainable, as the jurisdiction of civil courts is not barred unless expressly or impliedly stated. The Court clarified that Sections 23 and 25 of the Societies Registration Act, 1860 pertain to audit and eviction disputes, respectively, and do not preclude members from seeking relief in civil courts under Section 9 of the Code of Civil Procedure, 1908. Consequently, the appeal by the society was dismissed, affirming the lower courts' decisions.