I. Nelson & Anr vs Kallayam Pastorate & Ors

The Supreme Court addressed the registration status of the Indian Evangelical Lutheran Church under the Tamil Nadu Societies Registration Act, 1975, and the implications of its registration under the Societies Registration Act, 1860. The Court held that the Church's registration under the 1860 Act is deemed valid under Section 53 of the 1975 Act, provided its bye-laws are not inconsistent with the new Act. The Court emphasized the necessity of compliance with registration requirements to avoid the society being deemed defunct, thereby affirming the High Court's findings regarding the need for proper elections and management.