Can a member demand 18 years of minutes and accounts? Bombay High Court, Kumar City Residents CHS v. Mansingh Yadav (2025)

A member writes to the secretary asking for copies of the minutes of every general body and committee meeting going back to 2006, along with the profit and loss accounts for those years. The committee's instinct is familiar: those records are from before this committee's time, and surely a period that old is none of a current member's business. A short order of the Bombay High Court in November 2025 shows how badly that instinct can end.

The case in brief

Kumar City Residents Co-operative Housing Society Ltd. challenged an order against it in Writ Petition No. 5767 of 2025 before the Bombay High Court (Amit Borkar, J.), decided on 19 November 2025 (2025:BHC-AS:49800). The respondents were Mansingh Yadav, a member of the society, and others.

On 13 November 2024 the member applied under Section 154B(8) of the Maharashtra Co-operative Societies Act, 1960 for six listed documents. The Registrar heard the society and, by an order dated 23 December 2024, directed it to furnish all six within fifteen days. The society's appeal to the Divisional Joint Registrar was dismissed on 4 March 2025, and it then went to the High Court.

The society's argument was that it had already supplied three of the six items, and that the other three related to a period for which the member had no right to seek information.

What the court decided

The High Court dismissed the petition, so the Registrar's direction stands. It recorded that the society had, prima facie, already given the minutes of the annual general meetings from 2017 to 2024 and the audited balance sheets for 1 April 2017 to 31 March 2024. The dispute was about the earlier period: minutes of annual general body meetings, special general body meetings and managing committee meetings, and profit and loss accounts, from 18 May 2006 to 2017.

The court held that these documents are "part of the mandatory records of the Society", that there was "no material to show that the Society is exempt from supplying them", and that there was no contrary evidence to limit the member's claim. Having examined clauses (1) to (6) set out at page 27 of the petition, it found that each document sought falls within Section 154B(8). It relied on the Bombay High Court's earlier decision in Yuvraj Dattatraya Patil v. Regional Joint Director (Sugar), Kolhapur, 2011 (4) Mh.L.J. 325, for the proposition that a member's right to obtain records is wide.

It also rejected the idea of partial compliance. Supplying the latest audit report did not settle matters while other documents remained outstanding:

> "The law does not allow selective compliance when the Registrar has passed a clear order to supply all the documents listed."

It fixed no fresh deadline and made no order as to costs.

Why it matters for your society

First, the Registrar's route under Section 154B(8) is real and quick: a written application produced an order with a fifteen-day deadline that survived appeal and a writ petition.

Second, "those are old records" did not work as an answer here. The society had already supplied seven years of records and then drew a line at 2017; with no material showing exemption, the line did not hold.

What your committee should do

1. 1Keep the books and registers listed in bye-law 141 complete, including the minutes book of the committee and the minutes book of the general body, and the subject files listed in bye-law 142. Bye-law 143 makes the Secretary responsible for keeping them up to date, unless the committee decides otherwise.
2. 2Keep all records at the society's premises, convenient to the secretary, as bye-law 123 requires.
3. 3Treat a member's written request as a request under bye-law 23, which gives members the right to inspect records free of cost and to take copies on payment of the fees in bye-law 171. The fee table lists, for example, minutes of general body and committee meetings at Rs 10 per page. Issue a fee receipt and the copies rather than a refusal.
4. 4Finalise minutes on the bye-law 108 timetable (draft minutes finalised by the committee within three months of the general body meeting, circulated to members within fifteen days of that committee meeting, observations invited within fifteen days, then final minutes entered in the minutes book), and have committee minutes signed and placed for confirmation under bye-law 136.
5. 5If the Registrar orders supply, comply fully with the whole order. Selective compliance is what failed in this case. If you genuinely contest part of it, say so in the appeal with material, not with a bare assertion that the period is too old.
6. 6Bye-law 174 lets a member take non-supply of copies of records, and tampering, suppression or destruction of records, to the Registrar, as happened here, after bye-law 172 (written complaint) and bye-law 173 (decision at the next committee meeting, notified within fifteen days).

Limits of this ruling

This is a short, eleven-paragraph order of a single judge, not a detailed judgment.

The court examined these six items and found, on this record, no material showing that the society was exempt and no contrary evidence limiting the member's right. That is a finding on the evidence before it, not a declaration that every record of every period must always be handed over.

The member made further submissions, which the court recorded without ruling on them. It made no finding on whether minutes can be denied to a member who did not attend the meeting, on Section 32 or Section 154B(23) of the Act, or on whether an actual transaction between the member and the society is a precondition for the clause about records of a member's transactions. The order also does not say where the "mandatory records" requirement comes from.

The model bye-laws fix no retention period for any record, which is why "the records are too old" is not, by itself, an answer. The 2026 amendment Rules add nothing on member access to records, so this question remains governed by the Act, the Registrar's powers and the bye-laws.