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Shri Ramtanu Co-Operative Housing ... vs State Of Maharashtra & Ors on 5 August, 1970

The State cannot compel a society to amend its bye laws, as such compulsion would defeat the very purpose of its formation. The inclusion of demolition and reconstruction in the statutory definition only confers an option on housing societies to amend their objects, if they so choose. It does 3 ::: Uploaded on - 19/12/2025 ::: Downloaded on - 19/12/2025 23:13:53 ::: wp8889-2024-J.doc not operate as a mandate. This position is supported by the judgment in Happy Home Co operative Housing Society Limited v. State of Maharashtra, reported in (2016) 2 Bom CR 462. The statutory definition must be read in the context of the object of a particular housing society. Unless the bye laws of the society contain demolition and reconstruction as one of its objects, such activity cannot be treated as its business. In the absence of such an object in the bye laws, redevelopment cannot be forced into the fold of the society's business merely on the strength of the amended definition. Section 154B(31)(1) contains a saving clause in respect of existing bye laws. It expressly provides that bye laws in force on the date of commencement of the Amendment Act of 2019 shall continue to apply until they are expressly modified or amended. This makes it clear that societies governed by Chapter XIII B are not deemed to have automatically amended their bye laws to include demolition and reconstruction as an object. The saving provision does not render Chapter XIII B inapplicable. However, it also does not create a legal fiction by which existing bye laws stand amended with immediate effect. As a consequence, resolutions relating to demolition and reconstruction cannot, by default, be treated as matters of management or business of such societies. Sub clause (2) of Section 154B(31) further provides that pending proceedings shall continue and be decided as if the said chapter had not been made applicable. This reinforces the legislative intent underlying the saving provision.
Supreme Court of India Cites 11 - Cited by 87 - A N Ray - Full Document

Bhoumik Co-Operative Housing Society ... vs Vina A. Siswawala(Deleted Since ... on 10 August, 2022

4. He submitted that a learned Single Judge of this Court, by order dated 6 October 2022 in Bhoumik Co operative Housing 4 ::: Uploaded on - 19/12/2025 ::: Downloaded on - 19/12/2025 23:13:53 ::: wp8889-2024-J.doc Society v. Vina Sisawala and others, has held that Section 154B(1) (17) is an enabling provision. It was further held that the amended definition of housing society would not apply where the existing bye laws do not include redevelopment as one of the objects, particularly in view of the saving clause under Section 154B(31). There can be several reasons why a housing society may consciously decide not to include demolition and reconstruction as one of its objects. That decision must be left to the collective wisdom of the society. A society may deliberately avoid making redevelopment part of its business, as doing so would attract the bar of civil court jurisdiction and exclude arbitration as a mode of dispute resolution, having regard to Sections 91 and 163 of the Act. Section 91 of the Act enumerates the disputes over which the Co operative Court has jurisdiction. This provision does not restrict the power of a society to deliberate or resolve upon matters beyond the subjects falling within such jurisdiction. Through its general body, a society may take decisions on various aspects, including those falling within its bye laws. There is a clear distinction between demolition and reconstruction of a society's existing building and redevelopment undertaken through a developer acting as an agent coupled with interest. The differences are significant.
Bombay High Court Cites 0 - Cited by 18 - R I Chagla - Full Document

Margaret Almeida And Ors. Etc vs Bombay Catholic Co-Optv.Hsg.Socy.& ... on 22 March, 2013

Funds raised by the developer are not raised as an agent of the society. Lending institutions do not have recourse against the society or the rehabilitation component on the premise of agency. Indian law recognises the concept of dual ownership, where a developer, upon payment of requisite premiums and utilisation of TDR, acquires ownership rights in the free sale component. For this reason, such a developer is treated as a promoter under the provisions of MOFA and RERA.The Supreme Court in Margret Almeida v. Bombay Catholic Co operative Housing Society Limited, reported in (2012) 5 SCC 642 , has held that a developer does not fall within the scope of Section 91(1)(c) or Section 93 of the Act.
Supreme Court of India Cites 15 - Cited by 8 - Full Document

Chirag Infra Projects Pvt Ltd vs Vijay Jwala Co-Operative Housing ... on 5 February, 2021

8. He submitted that this view finds support from the judgment of this Court in Chirag Infra Projects v. Vijay Jwala Co operative Housing Society Limited 2022 (2) All MR 484. In paragraph 12 of the said decision, this Court observed that a member is bound by the resolutions of the general body unless he challenges them by resorting to the remedies provided under the Maharashtra Co operative Societies Act. This principle applies even where the resolutions relate to redevelopment of the society property.
Bombay High Court Cites 0 - Cited by 16 - G S Patel - Full Document

Mohinder Kaur Kochar vs Mayfair Housing Private Ltd. & Ors on 1 August, 2012

9. He submitted that as regards the judgments relied upon by the petitioner to contend that redevelopment does not touch the business of the society, the reliance is misplaced. The petitioner has relied upon the decisions of the Division Bench of this Court in 7 ::: Uploaded on - 19/12/2025 ::: Downloaded on - 19/12/2025 23:13:53 ::: wp8889-2024-J.doc Mohinder Kaur Kochar v. Mayfair Housing Private Limited, Maya Developers v. Neelam R. Thakkar, and Parimal H. Solanki v. Bhauik Co operative Housing Society Limited. The factual context of those cases is materially different. In those matters, suits were instituted by developers seeking specific performance of development agreements executed in their favour. The question of jurisdiction under Section 91 arose in the context of claims made by developers under contractual arrangements. In those cases, the courts were not concerned with the validity of resolutions passed by the general body or with the legality of the conduct of general meetings. The discussion was confined to whether such disputes could be said to touch the business of the society. Those judgments do not consider, nor do they lay down any binding principle, in relation to the other categories expressly provided under Section 91, such as conduct of general meetings or management of the society. For this reason, the said judgments do not govern the controversy in the present case.
Bombay High Court Cites 18 - Cited by 23 - M S Shah - Full Document
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