Registrar Cane Cooperative Societies & Ors. v. Gurdeep Singh Narval (D) through LRs. & Ors., 2026 INSC 216 - UP Reorganization Act- Multi-State Cooperative Societies Act
Uttar Pradesh Reorganisation Act, 2000- Sections 87 and 93; Multi-State Cooperative Societies Act, 2002 - Section 103: Sugarcane Growers Cooperative Societies of Bajpur and Gadarpur, whose areas of operation were effectively confined to Uttarakhand pursuant to steps taken under Sections 87 and 93 of the Uttar Pradesh Reorganisation Act, 2000, could not be treated as deemed Multi-State Cooperative Societies under Section 103 of the Multi-State Cooperative Societies Act, 2002. (Para 26)
Multi-State Cooperative Societies Act, 2002 - Section 103: The deeming fiction under Section 103 is neither automatic nor universal, but is conditional upon factual determination of the objects of the concerned Society and it has to be ascertained whether the object of such Society extend to more than one State. The conceptual distinction between ‘objects’ and ‘area of operation’ and clarified that 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.
Interpretation of Statutes - Legal Fiction - A legal fiction must be strictly confined to the purpose for which it is created and cannot be extended beyond its legitimate field. Legal fictions are crafted tools, precise in purpose and limited in reach. (Para 22)
Interpretation of Statutes - The provisions contained in two statutes must be, if possible, interpreted in a harmonious manner to give full effect to both the statutes. (Para 24)
Case Info
Extracted Information
Case name and neutral citation:Registrar Cane Cooperative Societies & Ors. v. Gurdeep Singh Narval (Dead) through LRs. & Ors., 2026 INSC 216
Coram:Justice Pamidighantam Sri Narasimha and Justice Alok Aradhe (Judgment authored by Alok Aradhe, J.)
Judgment date:10 March 2026 (New Delhi)
Case laws and citations referred:
- State of Uttar Pradesh through Principal Secretary and Others v. Milkiyat Singh and Others, 2025 SCC OnLine SC 28027
- Naresh Shankar Srivastava v. State of Uttar Pradesh & Ors., (2009) 16 SCC 157
- In re: Interplay between Arbitration Agreements under Arbitration and Conciliation Act, 1996 and Stamp Act, 1899, (2024) 6 SCC 1
Statutes / laws referred:
- Uttar Pradesh Reorganisation Act, 2000 – especially Sections 87 and 93
- Multi-State Cooperative Societies Act, 2002 – especially Section 5, Section 22, and Section 103(1) with provisos as amended by Act 11 of 2023
- State Reorganisation Act, 1956 (Part II – generally referred in context of Section 103)
- Constitution of India – Part IX‑B (as inserted by the Constitution (Ninety-Seventh Amendment) Act, 2011) and Article 368(2) (context of validity of the 97th Amendment)
- U.P. Cooperative Societies Act, 1965 (as applied to Uttaranchal/Uttarakhand under Section 87 of the Reorganisation Act)
- Multi-State Cooperative Societies Act, 1984 (in context of Naresh Shankar Srivastava)
- Constitution (Ninety-Seventh Amendment) Act, 2011
- Multi-State Cooperative Societies (Amendment) Act, 2023 (Act 11 of 2023)
Brief summary (three sentences)
The Supreme Court held that the Sugarcane Growers Cooperative Societies of Bajpur and Gadarpur, whose areas of operation were effectively confined to Uttarakhand pursuant to steps taken under Sections 87 and 93 of the Uttar Pradesh Reorganisation Act, 2000, could not be treated as deemed Multi-State Cooperative Societies under Section 103 of the Multi-State Cooperative Societies Act, 2002. Emphasising that the deeming fiction in Section 103 is neither automatic nor universal and requires that the society’s objects (not merely its area of operation or membership) extend to more than one State, the Court found that these societies’ bye-laws showed only local, single‑State objectives, and that completed reorganisation actions under the Reorganisation Act could not be unsettled. Consequently, the Court quashed the Uttarakhand High Court’s judgment dated 14 March 2007, upheld the High Court’s order dated 5 September 2006 in the connected matter, and directed the State cooperative authorities to conduct elections to the societies under State cooperative law.
