In Brief
A Parsi community trust sought the Registrar's sanction to sell five of its immovable properties under section 14 of the Madhya Pradesh Public Trusts Act, 1951. The sale was approved by the trust's members via a transparent, two-layered democratic process and was based on a realistic assessment of its financial liabilities and charitable obligations. The Registrar rejected the application based on her subjective judgment of the trust's best interests. The High Court upheld the rejection. The Supreme Court held that the Registrar's powers are limited to considerations stated in the trust instrument, statute, or court directions; subjective notions of best interests cannot override a well-informed decision by a self-governed organization. The Court distinguished the narrower powers under the Madhya Pradesh Act from the wider supervisory role granted under the Bombay Public Trusts Act and reaffirmed that state control of autonomous trusts cannot undermine freedom of association. The appeal was allowed and the Registrar's order was set aside.
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