REGISTRAR CANE COOPERATIVE SOCIETIES & ORS. versus GURDEEP SINGH NARVAL (DEAD) THROUGH LRS. & ORS.
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[2026] 3 S.C.R. 301 : 2026 INSC 216 Registrar Cane Cooperative Societies & Ors. v. Gurdeep Singh Narval (Dead) Through Lrs. & Ors. (Civil Appeal No. 8743 of 2013) 10 March 2026 [Pamidighantam Sri Narasimha and Alok Aradhe,* JJ.] Issue for Consideration Whether Sugarcane Growers Cooperative Societies, Bajpur and Gadarpur, situated in Udham Singh Nagar, District of Uttarakhand could be treated as Multi-State Cooperative Societies by operation of s.103 of Multi-State Cooperative Societies Act, 2002, despite their prior reorganisation and confinement of their area of operations to a single State, under the statutory framework governing State reorganisation. Headnotesβ Uttar Pradesh Reorganisation Act, 2000 β ss.87, 93 β Multi-State Cooperative Societies Act, 2002 β s.103 β Sugarcane Growers Cooperative Societies, Bajpur and Gadarpur, situated in Udham Singh Nagar, District of Uttarakhand, if could be treated as Multi-State Cooperative Societies by operation of s.103 of 2002 Act, despite their prior reorganisation and confinement of their area of operations to a single State, under the statutory framework governing State reorganization: Held: Sugarcane Growers Cooperative Societies, Bajpur and Gadarpur are not Multi-State Cooperative Societies under the 2002 Act β Residence of the members or the geographical spread of activity cannot substitute the statutory requirement that principal objects must themselves be Multi States in character β In the instant appeals on careful scrutiny of bye-laws, it is evident that the object of the society are confined to safeguarding and promoting the interests of local canegrowers and their objects do not evince any intention to serve the members across the State boundaries β In view of the statutory scheme and chronology of events, decisions taken to reorganize the societies on bifurcation of erstwhile State of Uttar Pradesh are valid in view of ss.87 and *βAuthor 302 [2026] 3 S.C.R. Supreme Court Reports 93 of Reorganisation Act β s.103 of 2002 Act neither operates automatically nor could it retrospectively invalidate the completed actions undertaken under the Reorganisation Act β Provisions contained in two statutes must be, if possible, interpreted in a harmonious manner to give full effect to both the statutes β The overriding effect of Reorganisation Act and effect of s.103 of the 2002 Act necessitates a harmonious construction by which operation of legal fiction has to be restricted, in cases where action for reorganisation of the Societies has already been taken and in respect of the Society whose objects and area of operation are confined to a single State β A deeming provision u/s.103 of 2002 Act cannot unsettle such completed action for reorganisation, by virtue of ss.87 and 93 of the Reorganisation Act β In the absence of multiple State objects in the bye-laws of the Societies, the same cannot be treated as Multi-State Cooperative Societies, as statutory pre-conditions for invoking s.103 of 2002 Act are absentΒ β Judgment dtd.14.03.2007 passed by the High Court is quashed and set aside while the judgment dtd.05.09.2006 passed in C.A. No.8746 of 2013 by High Court is upheld β Authorities under the State Cooperative law shall take steps to conduct the elections of the Societies expeditiously β U.P. Cooperative Societies Act, 1965 β Interpretation of Statutes. [Paras 23, 24, 26] Multi-State Cooperative Societies Act, 2002 β s.103 β Deeming fiction under β Legal fiction is confined to the purpose for which it is created and cannot be extended beyond its legitimate field: Held: s.103 of 2002 Act introduces a deeming fiction, whereby certain societies affected by reorganisation may be treated as Multi-State Cooperative Societies β A legal fiction must be strictly confined to the purpose for which it is created and cannot be extended beyond its legitimate field β Legal fictions are crafted tools, precise in purpose and limited in reach β The deeming fiction created u/s.103 of the 2002 Act cannot, in any case be construed in isolation so as to override the express statutory scheme contained in Reorganisation Act, which is an enactment governing all legal, administrative and institutional consequences arising from bifurcation of erstwhile State of Uttar Pradesh β The Reorganisation Act has also a non-obstante clause i.e., s.93 β The deeming fiction which though provides for a contingency on bifurcation of State, embodied
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