Orissa High Court
Faculty Association vs Union Of India And Ors. .... Opposite ... on 20 June, 2025
Author: S.K. Panigrahi
Bench: S.K. Panigrahi
Signature Not Verified
Digitally Signed
Signed by: BHABAGRAHI JHANKAR
Reason: Authentication
Location: ORISSA HIGH COURT, CUTTACK
Date: 24-Jun-2025 16:53:36
IN THE HIGH COURT OF ORISSA AT CUTTACK
W.P.(C) No. 15349 of 2024
(In the matter of an application under Articles 226 and 227 of the
Constitution of India, 1950).
Faculty Association, AIIMS, .... Petitioner(s)
Bhubaneswar & Ors.
-versus-
Union of India and Ors. .... Opposite Party (s)
Advocates appeared in the case through Hybrid Mode:
For Petitioner(s) : Mr. Subir Palit, Senior Advocate
Along with
Mr. A. Kejriwal, Advocate
Ms. Ananya Pradhan, Advocate
For Opposite Party (s) : Mr.B. S. Rayaguru,
Sr. Panel Counsel,
Mr. Aurovindo Mohanty,
Advocate
CORAM:
DR. JUSTICE S.K. PANIGRAHI
DATE OF HEARING:-12.05.2025
DATE OF JUDGMENT:-20.06.2025
Dr. S.K. Panigrahi, J.
1. In this Writ Petition, the Petitioners seek a direction from this Court to quash the Executive Director's order treating it as unrecognized and Page 1 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 to restore its status as a recognized service association, along with consequential privileges, under the CCS (RSA) Rules, 1993.
I. FACTUAL MATRIX OF THE CASE: 2. The brief facts of the case are as follows: (i) The Faculty Association of AIIMS, Bhubaneswar (FAIIMS) is a
registered body under the Societies Registration Act and has functioned at the institute since 2014. The Association has historically carried out activities pursuant to its bye-laws and has interacted with the AIIMS administration on faculty-related matters.
(ii) On 21.12.2023, the Executive Director of AIIMS Bhubaneswar issued an order stating that the Faculty Association does not have formal recognition under the Central Civil Services (Recognition of Service Associations) Rules, 1993 [CCS (RSA) Rules]. This was followed by a subsequent communication dated 26.04.2024 reiterating the deemed de-recognition. The AIIMS administration contends that no documentary proof of recognition under Rules 4, 5, or 6 of the CCS (RSA) Rules was ever submitted by the Association despite multiple reminders and a show-cause notice issued on 05.04.2023.
(iii) The petitioners challenge the authority of the Executive Director to de-
recognise the Association, arguing that only the Central Government has jurisdiction under the CCS (RSA) Rules to withdraw recognition. They further assert that the process adopted lacked compliance with principles of natural justice. AIIMS, on the other hand, maintains that the Executive Director, by virtue of being Secretary of the Institute and Governing Body under Section 11(2) of the AIIMS Act and Page 2 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 Regulation 35 of the AIIMS Regulations, 2019, acted within his jurisdiction.
(iv) The matter was initially brought before the Central Administrative Tribunal, which declined jurisdiction. The petitioners then filed W.P.(C) No. 7978 of 2024 before the High Court, which directed the Executive Director to consider the petitioners' representation. The representation was considered, and the impugned order dated 26.04.2024 was passed by the Executive Director.
(v) The last election of the Faculty Association office bearers was held on 09.07.2022, for a two-year term under Clause 7.3 of the bye-laws. While the petitioners claim that ongoing legal proceedings and administrative restrictions impeded further elections, the AIIMS administration contests the legal validity of the petitioners' authority post-expiry of the two-year term and notes the absence of any formal update to the Registrar of Societies.
II. SUBMISSIONS ON BEHALF OF THE PETITIONERS:
3. Learned counsel for the Petitioners earnestly made the following submissions in support of his contentions:
(i) The Executive Director lacks statutory authority under the CCS (RSA) Rules, 1993 to de-recognise a service association. Rule 8 clearly vests such power solely with the Central Government, contingent upon notice and opportunity. The term "deemed de-recognition" is legally non-existent, and any such punitive action is ultra vires and void ab initio.Page 3 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication
Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36
(ii) The Executive Director's actions infringe upon the petitioners' fundamental right to form associations under Article 19(1)(c) of the Constitution. The CCS (RSA) Rules were enacted to protect such rights, and the denial of recognition, restriction of association activities, and show cause proceedings violate both constitutional protections and statutory safeguards.
(iii) The impugned actions are retaliatory in nature, stemming from the Association's raising of legitimate concerns regarding institutional governance, including corruption, drug shortages, and irregular appointments. These measures amount to a colourable exercise of power intended to silence dissenting voices.
(iv) AIIMS has previously issued written communications (e.g., letter dated 13.08.2021) affirming recognition of FAIIMS. Salary deductions towards Association membership, official file notings, and the Association's filing of income tax returns further substantiate its continued recognition. The petitioners' tenure has not legally expired due to the sub-judice nature of the matter, supported by judicial precedents.
(v) The essential function of de-recognising a service association cannot be delegated to an institutional authority like the Executive Director, especially when the parent statute does not authorize it. III. SUBMISSIONS ON BEHALF OF THE OPPOSITE PARTIES:
4. The Learned Counsel for the Opposite Parties earnestly made the following submissions in support of his contentions: Page 4 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication
Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36
(i) The writ petition is alleged to be based on disputed facts such as recognition status and election validity, which can only be adjudicated through civil proceedings requiring evidence. Petitioners allegedly lack locus standi due to expiry of tenure and absence of a valid mandate or resolution.
(ii) FAIIMS's claim to recognition is termed as merely oral and unsupported by any official recognition order or document.
Occasional administrative interactions (e.g., salary deductions or meeting invitations) do not amount to formal recognition under CCS (RSA) Rules.
(iii) The decision of 21.12.2023 and the follow-up order dated 26.04.2024 were passed only after show-cause notice and opportunity to be heard. In the absence of recognition, the Executive Director validly declared the Association as deemed derecognized to maintain institutional discipline.
(iv) The Association is alleged to have violated Rules 5-7 of the CCS (RSA) Rules by directly lobbying political persons and operating without proper election approval from the Registrar. Their conduct is said to be unauthorized, disruptive, and contrary to Rule 6, which prohibits political influence.
(v) The 2022 election result has not been submitted to or approved by the Registrar under Section 4 of the Societies Registration Act. In absence of such compliance, the petitioners' authority to represent FAIIMS is questioned.
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Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36
(vi) Recognition under CCS (RSA) Rules must be formally issued by the Director, who is empowered as Secretary of the Governing Body. In the absence of a written order of recognition from the Director, the Association cannot claim protected status or enforce fundamental rights under Article 19(1)(c).
IV. COURT'S REASONING AND ANALYSIS:
5. Heard Learned Counsel for parties and perused the documents placed before this Court.
6. From the pleadings and submissions, the principal questions that arise are: (i) Whether FAIIMS enjoys any legal status as a "recognized" service association under the CCS (RSA) Rules, 1993, and if not, whether it can claim any enforceable right via writ proceedings to prevent the opposite parties from treating it as unrecognized; (ii) Whether the Executive Director of AIIMS had the authority to issue the impugned "de-recognition" order under Rule 8 of the CCS (RSA) Rules, and the effect of any procedural irregularity in this regard; (iii) Whether the action of the opposite parties violates the petitioner's fundamental rights, particularly the right to form associations under Article 19(1)(c) of the Constitution; and (iv) To what relief, if any, the petitioner is entitled. These points are addressed in turn.
7. It is undisputed on record that no formal recognition was ever granted to FAIIMS under the procedure prescribed by the CCS (RSA) Rules, 1993. These Rules, framed by the Central Government in exercise of executive powers governing service conditions, lay down a detailed mechanism for according recognition to service associations Page 6 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 of government employees. In brief, Rule 3 defines the scope, and Rules 4 to 6 stipulate the eligibility conditions and process for recognition. One key requirement is that the Association must represent a certain proportion of the employees of the category concerned, for example, at least 35% of the employees in that category for primary recognition. The Association must apply to the Government with its memorandum of association, bye-laws, and a list of members, and it must furnish an undertaking to fulfill conditions such as democratic elections of office-bearers, financial accountability, and adherence to the Constitution and laws. Recognition, if granted, is communicated through a formal order or certificate issued by the competent authority (usually the concerned Ministry or Department of the Central Government) and is typically valid for a fixed period, subject to renewal upon verification of continued support and compliance.
8. In the present case, FAIIMS has been unable to produce any order or notification of the Central Government recognizing it under these Rules. There is no evidence that FAIIMS ever secured the mandatory 35% membership of the relevant cadre or that it ever applied through proper channels for recognition. In fact, it was fairly evident that the petitioner Association could not produce any tangible or formal proof of recognition granted under the CCS (RSA) Rules, 1993. While it sought to rely on past administrative conduct to suggest de facto acceptance, the absence of a statutory recognition order fatally undermines the foundation of its claim. In law, one cannot be 'de- Page 7 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication
Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 recognized' if one was never recognized in the first place. Any enforcement of rights through a writ of mandamus requires the claimant to establish an existing legal right. Here, absent formal recognition, FAIIMS cannot point to any statutory or legal right to continue as a recognized body. The entire edifice of the petitioner's challenge, which presumes that it enjoyed a recognized status that was withdrawn, collapses on this foundational fact.
9. Given the lack of statutory recognition, the petitioner's plea for relief under Article 226 must fail at the threshold. The writ jurisdiction of this Court, especially in matters of mandamus, is meant to enforce existing legal rights or performance of legal duties. The CCS(RSA) Rules, 1993 do not confer any legal status on an unrecognized association; on the contrary, they explicitly bar unrecognized associations from certain privileges, such as participation in official consultative machinery or use of government facilities.
10. In this context, it is apposite to refer to the decision of the Supreme Court in the case of D.K. Chhangani and Ors. v. NityaRanjan Mukherjee and Ors.1wherein the Court underscored the statutory framework laid down under the Central Civil Services (Recognition of Service Associations) Rules, 1993, and held that associations seeking to represent service personnel must first obtain recognition in accordance with the prescribed conditions under Rule 5. The relevant excerpt is produced below:
1
(1996) 10 SCC 694.Page 8 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication
Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 "It would, thus, be seen that if there are more than one rival unions of the Service employees, the Government of India have evolved a policy as to how the Service Associations required to be recognised by the appropriate authority should represent the interest of the members of the respective unions. In this view, it would be open to the appropriate union to approach the Government in the light of the above rules and seek recognition in accordance with law to avoid any future litigation in this behalf."
11. The Court made it clear that the right to represent employee interests is not inherent but is contingent upon formal recognition by the competent authority. The recognition mechanism serves as a regulatory filter to ensure legitimacy and representativeness, and the absence of such recognition disentitles any association from claiming rights or status as a representative body. The principle laid down therein squarely applies to the present case, where the petitioner Association has failed to establish any formal grant of recognition, thereby undermining the legal basis of its claims.
12. The petitioner invokes the doctrine of legitimate expectation, arguing that the Institute's past conduct effectively "acknowledged" FAIIMS. However, a legitimate expectation cannot override clear statutory provisions. There can be no estoppel against a statute. The CCS (RSA) Rules mandate formal recognition by the Government; administrative leniency or oversight cannot create recognition in the eye of law. Thus, whatever informal arrangements existed, they do not translate into an enforceable legal right that this Court can protect. The absence of recognition is sufficient to dismiss the writ petition. Page 9 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication
Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36
13. Notwithstanding the above conclusion, this Court considers it important to address the manner in which the Executive Director issued the impugned "de-recognition" order, so that the correct legal procedure is clarified. Rule 8 of the CCS (RSA) Rules, 1993 governs withdrawal of recognition. In essence, it provides that the Central Government (through the competent authority) may withdraw the recognition of a service association if it fails to observe the conditions subject to which recognition was granted, or for other specified reasons (such as engaging in undesirable activities). The Rule typically entails a due process: a show-cause notice to the association, an opportunity to be heard, and a reasoned decision by the Government. In the present case, the Executive Director invoked Rule 8 and unilaterally declared FAIIMS "de-recognized." This action, in substance, was beyond the scope of the Executive Director's authority. The power to grant or withdraw recognition lies with the Central Government, not with the head of a local unit or institute.
14. The Delhi High Court in Central PWD Engineers Association v.
Union of India2dealt with a somewhat analogous situation where a departmental officer issued an Office Memorandum treating an association as unrecognized without the concurrence of the Central Government. It was held that such a unilateral action was not in accordance with the Rules and was liable to be set aside. The relevant excerpts are produced below:
2
2023:DHC:3622-DB.Page 10 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication
Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 "26. The claim of petitioners is based upon the fact that the petitioner Association was entitled to continuation of recognition in accordance with CCS (RSA) Rules, 1993 but the same has been intentionally delayed by the respondents.
The rights and privileges of the petitioner Association and office bearers could not be left in limbo pending the request for continuation of recognition. It needs to be appreciated that the steps were taken on behalf of the petitioner Association for continuation of recognition vide various communications though after a delay of about one year and eight months. However, thereafter the matter was expected to be dealt expeditiously by the respondents. The right of continuation of a recognized Association should not have been delayed for such a considerably long period thereby denying the office bearers as well as the Association of the privileges. In such an eventuality, the very object of forming an Association of the employees stands patently denied and becomes illusory, from the perspective of the employees despite existence of CCS (RSA) Rules, 1993. The respondents were expected to adhere and take expeditious decision regarding the continuation of recognition of petitioner Association by the Competent Authority. We have already set aside OM dated January 09, 2019 to the extent of treating the petitioner Association as "unrecognized", as the decision was not issued with the approval of the Competent Authority as provided under the CCS (RSA) Rules, 1993 but was only taken at the level of DG, CPWD.
This court has ample power under Article 226 of the Constitution of India in appropriate cases to compel the performance of the obligation by the respondents for compliance of grant/continuation of recognition under CCS (RSA) Rules, 1993. The recognition finally appears to have been granted to the petitioner Association in 2021 for a period of five years from the date of issue of the letter but the decision for the period 2009 to 2021 still needs to be reconsidered by the Competent Authority in accordance Page 11 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 with law, in view of setting aside of OM dated January 09, 2019 to aforesaid extent. We accordingly deem it appropriate to direct the Competent Authority/respondents to take an appropriate decision in respect of the continuation of recognition in respect of petitioner Association from 2009 till 2021, in accordance with law."
15. By the same token, the Executive Director of AIIMS Bhubaneswar had no competence to suomotu "de-recognize" FAIIMS, especially when FAIIMS had never been recognized by the competent authority in the first place. The proper course for the opposite party, if of the view that FAIIMS ought not to be dealt with as a recognized association, was to refer the matter to the Ministry or follow the procedure under Rule 8, which presupposes an existing recognition to withdraw). In issuing the impugned declaration in the form he did, the Executive Director acted in excess of his jurisdiction.
16. The finding that the Executive Director had no authority to issue a de-
recognition order might have, in other circumstances, led the Court to quash that order. Indeed, the petitioner has succeeded in demonstrating a procedural illegality in the impugned action: the use of Rule 8 by an unauthorized official. However, as discussed in the earlier paragraphs, correcting this procedural flaw would not confer any positive rights upon the petitioner. At best, the Court could set aside the Executive Director's letter for want of authority; but even if that is done, FAIIMS would remain in the position of an unrecognized association unless and until the Central Government affirmatively grants it recognition. In other words, quashing the impugned order Page 12 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 would only result in removing the taint of "de-recognition". It would not amount to granting recognition or creating any enforceable status for FAIIMS. Since the core issue is the lack of recognition, the petitioner would ultimately be left with no remedy even if the impugned order is invalidated. In such a scenario, the Court may decline to issue a futile writ. Nonetheless, to dispel any doubt, it is clarified that the impugned order dated 15.03.2024 shall be treated as having no legal effect (having been issued without competence), but this declaration is purely academic given the petitioner's unrecognized status. The bottom line is that FAIIMS currently has no legal recognition; pro tanto, it has no right to be treated as a recognized association, and therefore no right capable of enforcement through this writ petition.
17. The petitioner has passionately invoked Article 19(1)(c) of the Constitution, which guarantees to all citizens the fundamental right to form associations or unions. There is no quarrel with the proposition that the members of FAIIMS, as citizens and government employees, enjoy the freedom to form an association for the furtherance of their common interests. Any outright ban or unreasonable restriction on the formation of such an association would indeed offend Article 19(1)(c), subject to permissible restrictions in Article 19(4). In the Central PWD Engineers Association (Supra) it was aptly held as under:
"The primary objective of the CCS (RSA) Rules, 1993 is of granting recognition to any Service Association in order to encourage legitimate union activities for enabling the negotiations by the representative body, if so required and Page 13 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 maintenance of harmonious relationship between the government and employees. The government servants cannot be excluded from the protection of the rights guaranteed by part III of the Constitution though the duties which they may discharge as a public servant might involve restrictions of freedom in terms of Article 19 of the Constitution of India. By virtue of Article 19(1)(c) of the Constitution of India, the right to form Association or Union or Cooperative Societies is a fundamental right even though the recognition of such Associations by the government may not be a fundamental right."
18. In the present case, however, the opposite parties have not attempted to disband FAIIMS or interfere with its existence. The Association is free to continue as a voluntary body of like-minded individuals. What is at stake is recognition by the Government, which is a distinct concept. The fundamental right to form an association does not entail a right to compel the government to grant that association official recognition or negotiation privileges. In other words, while individuals have freedom to associate, the recognition of that association by the State, which carries with it certain special privileges and obligations, is a matter of government policy and statutory regulation, not a fundamental right. Recognition under the CCS (RSA) Rules is essentially an administrative facilitation, it enables a channel of communication and representation between employees and the Government. The denial or absence of such recognition does not take away the right of the individuals to continue to form and operate their association privately; it only means the Government is not bound to deal with that association officially. Therefore, the petitioner's Article Page 14 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 19(1)(c) argument, though evocative, does not advance its case for a writ of mandamus. So long as the opposite parties are not prohibiting the existence or peaceful activities of FAIIMS, there is no infringement of the constitutional freedom of association. What the petitioner really seeks is a discretionary privilege, something Article 19(1)(c) does not guarantee.
19. The Court also agrees with the opposite parties' submission that informal administrative conduct cannot substitute for formal statutory recognition. The petitioner emphasized past instances where the AIIMS administration engaged with FAIIMS in a manner similar to dealing with recognized associations, such as deducting membership fees through payroll. While such practices may have been allowed, they carry no legal sanctity in the absence of compliance with Rules 4- 6 of the CCS (RSA) Rules. It appears that the local AIIMS authorities, perhaps in an effort to maintain cordial relations with the faculty, extended certain facilities to FAIIMS. However, those acts were ultra vires to the extent they presumed a status for FAIIMS that the Government of India had never formally accorded. Neither acquiescence nor lapse by administrative officials can create a right contrary to the Rules. The Central Government's policy on recognition of service associations, as reflected in the 1993 Rules, is aimed at ensuring that only representative and accountable associations are conferred recognition, in order to facilitate effective dialogue and prevent a multiplicity of unions.
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20. Allowing an unrecognized association to enjoy the fruits of recognition by default would undermine this policy and render the Rules obsolete. Thus, the Court cannot accept the plea that FAIIMS's de facto dealings with the institute entitle it to de jure recognition. If at all, the petitioner's recourse is to seek recognition by following the procedure laid down, not to bypass it by invoking equitable doctrines.
21. This episode highlights a curious disregard for the applicable legal framework. The Faculty Association has functioned since 2014 without showing any serious engagement with the Central Civil Services (Recognition of Service Associations) Rules, 1993. These rules were not introduced yesterday; they have governed the field for decades. On the other hand, the Executive Director has purported to withdraw a recognition that was never formally granted, invoking a power that rests with the Central Government. It seems both parties have been operating in parallel, guided more by habit and informal arrangements than by the applicable law. While one appreciates that academic institutions are primarily driven by pedagogical goals, regulatory literacy is not optional for bodies exercising public functions. Good intentions do not cure procedural invalidity, and institutional habit is not a substitute for statutory recognition.
22. Going forward, both parties might consider reading the rules before quoting them. The Faculty Association has spent over a decade in operation without once knocking on the door of formal recognition, and the Executive Director has attempted to pull the rug from under a carpet that was never laid to begin with. This is not a legal conflict so Page 16 of 18 Signature Not Verified Digitally Signed Signed by: BHABAGRAHI JHANKAR Reason: Authentication Location: ORISSA HIGH COURT, CUTTACK Date: 24-Jun-2025 16:53:36 much as a bureaucratic pantomime, complete with a generous disregard for the scheme of the CCS (RSA) Rules. Institutions like AIIMS, which pride themselves on academic rigour and public service, cannot afford to wander through regulatory fog. A basic acquaintance with the law is not an aspirational standard, it is the bare minimum. When both the governed and the governing are this far removed from the legal framework that binds them, confusion is not an accident, it is the system.
V. CONCLUSION:
23. In sum, the Court finds that the petitioner Association (FAIIMS) was never formally recognized in accordance with the CCS (RSA) Rules, 1993. Consequently, it has no legal or statutory right to claim the status or privileges of a recognized service association. The Executive Director's impugned order dated 15.03.2024, purporting to de- recognize FAIIMS, was issued without competent authority; yet, setting aside that order would not avail the petitioner, since one cannot lose what one never legally possessed. The fundamental right to form associations under Article 19(1)(c) remains intact for the members of FAIIMS, but that right does not translate into a right to be granted government recognition. No enforceable right of the petitioner has been infringed so as to warrant the intervention of this Court under Article 226. The appropriate course for the petitioner, if it desires official recognition, is to comply with the requisite conditions and pursue recognition through the proper statutory procedure, not to seek a short-circuit through judicial fiat.
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24. For the reasons aforestated, the Writ Petition is disposed of with the direction that the Petitioner's Association shall apply to the Government with all documents (i.e. Memorandum of Association, Bye-law, etc.) seeking formal recognition and the appropriate Government shall take steps to formally recognize the Association within one month from the date of submission of the application.
25. Interim order, if any, passed earlier stands vacated.
(Dr.S.K. Panigrahi) Judge Orissa High Court, Cuttack, Dated the 20th June, 2025/ Page 18 of 18