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Supreme Court of India 2025-05-03 partly_allowed

Dr. Vimal Sukumar vs D. Lawrence & Ors

Bench: 2 — Bela M. Trivedi, Satish Chandra Sharma

In Brief

The Supreme Court examined four civil suits filed under Section 92 CPC regarding management of the Church of South India (CSI), an unregistered ecclesiastical body with 4.5 million members. The disputes arose from the 2020 election of an allegedly scandal-tainted Moderator and subsequent constitutional amendments increasing retirement age from 67 to 70 years. The Court held that while the Special Meeting convening these amendments was duly held, the amendments were not validly ratified by two-thirds of Diocesan Councils due to procedural deficiencies in certain dioceses. Consequently, the Moderator's election was invalid. Other office bearers' elections remained valid due to significant victory margins. The Court affirmed that leave under Order 1 Rule 8 CPC is curable if absent but crucial for ensuring binding effect on all members.

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Civil Procedure Church Administration Constitutional Law Election Law Interim Relief Representative Suits Unregistered Associations

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