DR. VIMAL SUKUMAR versus D. LAWRENCE & ORS.

Citation: [2025] 5 S.C.R. 1731 · Decided: 02-05-2025 · Supreme Court of India · Bench: BELA M. TRIVEDI · Disposal: Disposed off
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Judgment (excerpt)

[2025] 5 S.C.R. 1731 : 2025 INSC 622
Dr. Vimal Sukumar  
v. 
D. Lawrence & Ors.
(Civil Appeal No(s). 6264-6266 of 2025)
02 May 2025
[Bela M. Trivedi and Satish Chandra Sharma,* JJ.]
Issue for Consideration
The instant appeals are arising out of the two impugned orders 
dated 27.02.2024 and 12.04.2024 by which the Division Bench of 
the High Court declared re-election of all the office bearers since it 
was held that the electoral college itself was flawed and appointed 
committee of administrators to conduct re-elections. Furthermore, 
it was held that the amendments to the bye-laws had not been 
carried out in accordance with the procedure prescribed in the 
Constitution of Church of South India (CSI) and it was held that 
the Special Meeting of the Synod held on 7th and 8th March 2022 
was not duly convened. The key issues that arise for consideration 
in the present appeals are as follows: (i) The validity of the Synod 
meeting convened on 07.03.2022, where certain amendments 
to the CSI Constitution were approved; (ii) The validity of the 
amendments to the Constitution and Bye-Law of the CSI; (iii) The 
validity of the Election of the Moderator; (iv) Whether the elections 
of other office bearers i.e. Deputy Moderator, General Secretary 
and Treasurer should be set aside due to alleged irregularities in 
the Electoral College; (v) Whether there should be an appointment 
of the Committee of Administrators to conduct fresh elections; (vi) 
Whether suits filed without obtaining leave under Order 1 Rule 8 
of CPC are maintainable. 
Headnotes†
Election – Constitution of Church of South India – Chapter XIII – 
The validity of the Synod meeting convened on 07.03.2022, 
where certain amendments to the CSI Constitution were 
approved:
Held: This Court is of the considered opinion that the Special 
Meeting of the Synod on 07.03.2022 was duly convened – By 
* Author
1732
[2025] 5 S.C.R.
Supreme Court Reports
going through the minutes of the Special Executive Committee of 
the Synod meeting held on 12.01.2022, it can be observed that: 
(a) Executive Committee of the Synod decided to send a resolution 
for the proposed constitutional and bye-law amendments to the 
Synod for the consideration and approval at its Special Session; (b) 
Executive Committee of the Synod decided to summon a special 
meeting of the Synod for the aforesaid purposes and to authorise 
the Moderator and other Officers of the Synod to fix the time and 
place of the meeting in consultation with the Bishops and (c) 
Executive Committee of the Synod decided to direct the General 
Secretary to prepare and circulate the proposed amendments to 
all the Bishops for forwarding the same to each and every member 
of the Synod in their respective dioceses – Thereafter, a Meeting 
Notice dated 10.02.2022 was issued by the General Secretary of 
CSI, informing all the members of the Synod that a decision to 
convene a Special Synod Meeting on 7th and 8th March, 2022 at 
Bishop Heber College has been taken by the Special Executive 
Committee – In the absence of provisions in the CSI Constitution 
regarding the manner of convening meetings of the Synod, a 25 
days’ notice was provided to the members of the Synod prior to 
the Special Meeting of the Synod – This chain of communication 
and procedural compliance further substantiates the fact that due 
process was followed in relation to the convening and conduct 
of the meeting – It can further be concluded that large numbers 
of the members attended the Special Meeting of the Synod and 
therefore the meeting cannot be said to have been conducted 
without notice – Therefore, it can prima facie be established that the 
Special Meeting of the Synod on 07.03.2022 was duly convened. 
[Paras 56, 56.1]
Election – Constitution of Church of South India – Chapter 
XIII – Amendment to the Constitution and Bye-laws – The 
validity of the amendments to the Constitution and Bye Law 
of the CSI:
Held: The present amendments to the CSI Constitution and its 
Bye-laws traces its origin in ordinary meeting of the Synod held 
on 14th and 15th January, 2020 – The Resolutions Committee’s 
report from that meeting directed the Constitution Revision 
Committee to develop the necessary amendments – Consequently, 
the Constitution and Bye-Laws Revision Committee of the Synod 
[2025] 5 S.C.R. 
1733
Dr. Vimal Sukumar v. D. Lawrence & Ors.
proposed amendments to the CSI Constitution and the Bye-Laws, 
following Rules 2 & 3 of Chapter XIII of the
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