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Supreme Court of India 2025-08-05 dismissed

OPERATION ASHA vs SHELLY BATRA & ORS

Bench: 2 — J.B. Pardiwala, R. Mahadevan

In Brief

Operation Asha, a registered charitable NGO providing health services, was sued under Section 92 CPC by two members alleging that officials diverted donor funds for personal benefit. The core issue was whether a registered society can be subject to a constructive trust. The Supreme Court held that while registered societies are not express trusts, they can be subject to constructive trusts when officials unlawfully siphon public donations. The Court upheld leave to sue, ruling that the society's governing body holds fiduciary duties to beneficiaries regardless of legal form, and that allegations of financial impropriety prima facie warranted court intervention under Section 92, though personal reliefs (like reinstatement) must be pursued separately.

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Charitable Trusts Section 92 CPC Societies Registration Act 1860 Constructive Trust Public Charities Fiduciary Duty NGO Governance Breach of Trust Representative Suits Equitable Remedies

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