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Swami Parmatmanand Saraswati & Anr vs Ramji Tripathi & Anr on 21 August, 1974

21. But, as held by the Apex Court in Swami Parmatmanand Saraswati (supra) and Vidyodaya Trust (supra), it is not every suit claiming the reliefs specified in Section 92 of the Code that can be brought under the section but only the suits which, besides claiming any of such reliefs, are brought by individuals as representatives of the public for vindication of public rights. In deciding whether a suit falls within Section 92 of the Code, the court must go beyond the reliefs and have regard to the capacity in which the plaintiffs are suing and to the purpose for which the suit is brought. The court below has not considered the question in this perspective.
Supreme Court of India Cites 5 - Cited by 121 - K K Mathew - Full Document

Mahant Pragdasji Guru Bhagwandasji vs Patel Ishwarlalbhai Narsibhai ... on 7 March, 1952

14. A suit under Section 92 of the Code is a suit of a special nature which presupposes the existence of a public trust of a religious or charitable character. Such a suit can proceed only on the allegation that there was a breach of such trust or that the direction of the Court is necessary for the administration of the trust and the plaintiff must pray for one or more of the reliefs that are mentioned in the section. It is only when these conditions are fulfilled that a suit could be brought in conformity with the provision of Section 92 of the Code. If the allegation of breach of trust is not substantiated or that the plaintiff had not made out a case for any direction by the Court for proper C.R.P.No.841/2019 11 administration of the trust, the very foundation of a suit under the section would fail (See Pragdasji Guru v. Ishwarlalbhai :
Supreme Court of India Cites 1 - Cited by 61 - B K Mukherjea - Full Document

Sugra Bibi vs Hazi Kummu Mia on 13 December, 1968

18. The three essential conditions to be satisfied to invoke Section 92 of the Code are : (i) the trust is created for public purposes of a charitable or religious nature, (ii) there was a breach of trust or a direction of the Court is necessary in the administration of such a trust, and (iii) the relief claimed is one or other of the reliefs enumerated therein. If any of the three conditions is not satisfied, the suit falls outside the scope of Section 92 of the Code (See Bishwanath v. Thakur Radha Ballabhji : AIR 1967 SC 1044, Sugra Bibi v. Hazi Kummu Mia : AIR 1969 SC 884 and Ashok Kumar Gupta v. M/s. Sitalaxmi Sahuwala Medical Trust : (2020) 4 SCC 321).
Supreme Court of India Cites 9 - Cited by 52 - V Ramaswami - Full Document

Vidyodaya Trust vs Mohan Prasad R & Ors on 27 February, 2008

21. But, as held by the Apex Court in Swami Parmatmanand Saraswati (supra) and Vidyodaya Trust (supra), it is not every suit claiming the reliefs specified in Section 92 of the Code that can be brought under the section but only the suits which, besides claiming any of such reliefs, are brought by individuals as representatives of the public for vindication of public rights. In deciding whether a suit falls within Section 92 of the Code, the court must go beyond the reliefs and have regard to the capacity in which the plaintiffs are suing and to the purpose for which the suit is brought. The court below has not considered the question in this perspective.
Supreme Court of India Cites 17 - Cited by 103 - A Pasayat - Full Document
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