The Constitution of India recognizes the significance of Co-operative Societies by incorporating them within Part III, i.e., Fundamental Rights, specifically under Article 19(1)(c). Co-operative Societies are also addressed in Part IV, which outlines the Directive Principles of State Policy.

In line with the objective of facilitating the systematic growth of the co-operative movement, the Maharashtra Co-operative Societies Act,1960 (“MCS Act”) was enacted. In 2011, Article 43B and Part IX-B (consisting of Article 243ZH – Article 243ZT) were inserted in the Constitution by the ninety-seventh constitutional amendment. As per Article 43B of the Constitution of India, it is the duty of the State to actively promote the voluntary formation, autonomous functioning, democratic control, and professional management of these societies. Part IX-B of the Constitution of India focuses on the co-operative societies and provides a comprehensive framework for their incorporation, regulation, and winding up. The process of election of board members is outlined in Article 243ZK. The provisions of this Part apply to multi-state cooperative societies with necessary modifications by the State. Further, this part extends to Union Territories, subject to specific provisions for territories without a Legislative Assembly. However, Part IX-B of the Constitution so far State Co-operative Societies are concerned has been struck down / quash by the Hon’ble Supreme Court in case of Union of India v. Rajendra N. Shah, 2021 SCC Online SC 474, decided on 20-07-2021. However, the State of Maharashtra had already amended the Maharashtra Co-operative Societies Act as mandatory by the Part IX-B of the Constitution of India.

Recognizing the substantial presence and influence of Co-operative Housing Societies within this sector, Chapter XIII-B was introduced into the Act in 2019.

Introduction

Under the MCS Act, different types of co- operative societies exist based on their objectives. Among them are Housing Co- operative Societies having members less than or upto 250 members as of March 31st of the preceding year, also known as Type “E” co- operative housing societies whereas the Housing Co-operative Societies having more than 250 members fall under Type “C” societies. Co- operative Housing Societies have the primary goal of providing affordable housing and / or related common amenities and/or services to its members. These societies consist of individuals who collaborate to construct or acquire residential properties. The Act contains provisions and regulations governing the establishment, functioning, and management of these societies.

This article focuses on the provisions of the Election Rules for Co-operative Housing Societies which fall under Type “E” Societies.

State Co-operative Election Authority

According to Section 73CB(1) of the Act, the State Co-operative Election Authority (“SCEA”) is the designated authority responsible for overseeing the preparation of electoral rolls and the conduct of all elections in co-operative societies. However, with the introduction of Chapter XIII-B for Housing Societies in the Act, an amendment was made to sub-section (11) of Section 73CB in 2019 by inserting second proviso, which provides that in case of Type “E” Co-operative Housing Societies, the elections of the Committee shall be conducted by the said housing society itself in the prescribed manner. Following the amendment, the Managing Committee and the Returning Officer of such a society became responsible for conducting elections for the committee.

To regulate the conduct of elections to the co-operative societies, the State Government introduced the Maharashtra Co-operative Societies (Election to Committee) Rules, 2014 (“Election Rules”). These Rules have replaced Maharashtra Specified Co-operative Societies to Elections to Committee Rules, 1971 and also Rules governing Notified Societies under Chapter V-A of MCS Rules. In 2021, the State Government amended the Election Rules by Maharashtra Co-operative Societies (Election to Committee) (Amendment) Rules, 2019 and laid down the procedure for conduct of election for housing societies in Maharashtra having less than or up to 250 members. This was done by primarily amending Rule 2 and 4 thereof, by adding Clause (V) to provide for a new category i.e. Type “E” societies as those with up to 250 members as of March 31st of the preceding year. To provide specific guidelines for the election process in Type “E” societies, a new part titled X-1A was introduced to the Election Rules. This part encompasses Rules 76-A to 76-R, which are exclusively applicable to Type “E” societies including Rules 1, 2, 4, 14, 17, 72, 78 to 86 of the Election Rules also made applicable vide Rule 76-R thereof. Rule 76-A states that the rules outlined in Part- X-1A are designed for Type “E” Societies, defined as housing societies with up to 250 members. Powers of the SCEA are specified in Rule 3 of the Election Rules and that by amendment in Rule 2(16) the power of the SCEA to appoint Returning Officer was taken away and the same is conferred upon the Managing Committee of the Society or the Registrar.

Appointment, Eligibility and Role of the Returning Officer

According to Rule 76-B of the Election Rules, the Managing Committee of a co-operative society is responsible for appointing a Returning Officer to conduct elections. The Returning Officer can be chosen from a panel of Returning Officers approved by SCEA and maintained by the Divisional Joint Registrar of Co-Operative Societies or from among the members of the Society who do not wish to contest the election. This appointment should be made at least sixty days before the existing Committee’s tenure expires, and the information should be communicated to the Registrar. The tenure of the Managing Committee extends for a period of five years, commencing from the initial meeting of the newly constituted Committee.¹

While explicit qualifications or experience requirements are not stipulated for assuming the role of a Returning Officer, it is essential that the individual is of legal age, mentally sound, and not disqualified by law. The Returning Officer cannot be an auditor, employee, or a member of the outgoing management committee.

The Divisional Joint Registrar may prescribe minimum qualifications and experience criteria for enrolment as a Returning Officer on the panel maintained by them and approved by the SCEA².

Furthermore, undergoing mandatory training is an essential requirement for the Returning Officer. This training can be obtained from the District Cooperative Housing Society Federation or any institute specified by the State Government. A training app called “Election CHS Training” in the Google Play Store is one of the many accessible training options, along with in-person training workshops and online training. Participants who successfully conclude the course are awarded a training certificate by the District Co-operative Housing Federations, verifying their eligibility to serve as Returning Officers.³

The Registrar has the ability to name a Returning Officer from the authorised panel in the event the Society’s committee fails to do so, and may do so suo moto or in response to a request from any member of the society.

As per Rule 14 r.w. rule 76-R of the Election Rules, it is general duty of the Returning Officer at any election to do all such acts and things as may be necessary for effectually conducting the election in the manner provided in these Rules and Bye Laws of the Society.

Provisional List of Voters

As per Rule 76-C of the Election Rules, the Provisional List of Voters, is a temporary compilation of names prepared and published by the Secretary or an Authorized Officer appointed by the Registrar of the society. It is created at least sixty days prior to the scheduled election and includes the names of Members and Provisional Members listed in the “I” Register and “J” Register of the Maharashtra Co-operative Societies Rules, 1961 (“Rules, 1961”). Joint Members and Associate Members are excluded from this list. Provisional List is prepared with the purpose to allow members to raise claims or objections regarding their inclusion. The Provisional List is posted on the notice board of the society, sent to the Registrar’s Office, and made accessible to all members through written notice with acknowledgment or by any electronic mode⁴.

As per Rule 76-D of the Election Rules, the provisional list shall contain the surname, name father or husband name, age, gender with addresses as recorded in Register of Members in Form E-3 and with such other particulars as may be necessary to identify the member.

Claims and Objections

According to Rule 76-E of the Election Rules, any member, associate member, joint member, or provisional member of the society, or any person having an interest in one of the society’s flats, may file claims and objections to the provisional list of voters. Such claims and objections must be made in writing stating the grounds on which claim is based or the objections are raised to the Returning Officer within 10 days of the provisional list’s publication. The Returning Officer will then conduct necessary inquiries and make a decision on each claim or objection or corrections within 10 days from the last date for receiving the claims or objections. The decision will be communicated in writing to the concerned individuals. Once all claims and objections have been resolved, the Returning Officer will publish the final list of voters within 10 days from the last date prescribed for receiving the claims/ objections in Form E 3(1). This final list will be displayed on the society’s notice board within two days of its preparation. The final list of voters is conclusive and an unamendable list.⁵

Transfer of Voting Rights

Rule 76-F of the Election Rules outlines the process for the transfer of voting rights in a society. Members of the society must submit written consent for transfer of voting rights to an associate or joint member within ten days of the publication of the provisional list of voters. This transfer is allowed under specific circumstances, such as when a relative is admitted as an associate member or when multiple individuals hold shares jointly.

In the case of legal entities like companies or firms, the authorized director, person, or partner must inform the Returning Officer of the representative appointed to vote on their behalf within the same ten-day period. Failure to communicate the representative’s name means the company or legal entity cannot exercise its voting rights.

Before the provisional list of voters is published, the secretary or office bearers have certain responsibilities. These include updating the associate member register and the ‘I’ and ‘J’ registers, informing all members about the amended definition of associate and joint members, promptly deciding on applications for associate membership, and issuing notices to inform legal entities and members about the transfer of voting rights as per the Election Rules.⁶

Election Program Guidelines

The election program for conducting elections in a society is governed by Rule 76-G of the Election Rules, which outlines the various stages and timelines. The Returning Officer is responsible for declaring the program within seven days of displaying the final list of voters. The program includes important dates such as the last date for making nominations, the date of publication of the list of nominations, the date of scrutiny of nominations, the date of publication of the list of valid nominations after scrutiny, the last date for withdrawing candidature, the date of publication of the final list of contesting candidates and allotment of election symbols, the date and time of the Special General Body Meeting or declaration of uncontested election, the date, time, and place for counting votes, and the date of declaration of voting results.

The election program must be published on the society’s notice board, and copies should be provided to all members either electronically, by hand delivery, registered post, or courier along with the notice of the Special General Body Meeting with date, time and venue in which the election will be conducted, if required. The Notice shall contain information regarding (i) no of vacancies to be filled by election and (ii) no of reserved seats as per the Act and Bye Laws.

The Returning Officer has the authority to determine the dates, times, and venues of each stage of the election program, ensuring maximum member participation. It is mandatory to call a Special General Body Meeting to declare the results of an uncontested election, and only the election matter should be discussed during the meeting. Even housing societies with fewer than 10 members must follow the election program outlined in the Election Rules. The Returning Officer does not have the authority to shorten the time periods specified in the election program. Before publishing the election program, the Returning Officer must finalize the dates and times of each stage, make necessary arrangements, ensure the availability of required resources and documents, and choose a convenient venue for the Special General Body Meeting. It is important to verify the addresses and email addresses of members to provide them with the election program information.

Nomination Form Procedure

The nomination process for candidates is governed by Rule 76- H of the Election Rules. As per the Rule, candidates must submit their nominations in FORM E-5, which shall be provided free of cost by the Returning Officer to the members. The nomination paper needs to be signed by two members listed in the final voter list, one acting as the proposer and the other as the seconder. The candidate is also required to include a signed declaration expressing their willingness to stand for the election. If contesting for reserved seats, the nomination paper must be accompanied by a copy of the Caste Certificate issued by the Competent Authority. Upon receiving the nomination papers, the Returning Officer assigns a serial number, certifies the date and time of receipt, and provides a written acknowledgment. The Returning Officer prepares and publishes a list of the confirmed nominations at the end of the nomination period. Individuals whose names are not on the final voter list or who are disqualified by the terms of the Act, Rules, or bye-laws are not eligible to be nominated as candidates.⁷

Symbols and Deposit Rules (Rule 76-I and 76-J of the Election Rules)

According to the Election Rules, the SCEA has provided a list of specified symbols that candidates may choose from during elections. However, symbols associated with recognized political parties are not allotted. If multiple candidates prefer the same symbol, it will be allocated on a “first come first serve” basis8. The Returning Officer is responsible for displaying the list of symbols specified by the SCEA and ensuring that symbols associated with recognized political parties are not allotted. If a candidate submits more than one nomination paper, the symbols mentioned in the declaration of the first nomination will be considered as their choice of symbols.

Candidates are required to deposit a specific amount as a nomination fee. Deposit for SC/ ST category is Rs.200/- and for other than SC/ ST category it is Rs.500/-

The procedure for the return or forfeiture of a candidate’s deposit is governed by Rule 70 r.w. Rule 76-R of the Election Rules. If a candidate’s name is not included in the list of contesting candidates due to rejection or withdrawal of their nomination, or in the case of the candidate’s death before the commencement of the poll, the deposit shall be returned, if possible, after the publication of the list or after the candidate’s death. If a candidate runs in the election and his or her deposit is not forfeited, it shall be reimbursed as soon as the election results are announced. On the other hand, a candidate’s deposit shall be forfeited to the Election Fund if they fail to get elected and receive less than one-tenth of the valid votes cast overall (or, in the case of elections for more than one member, one-tenth of the votes divided by the number of members to be elected).

Within two days after the election results, the forfeited deposit amount must be sent to the Election Fund of the SCEA’s bank account. The transfer details should be submitted to the Hon’ble Secretary of the SCEA in Pune.⁹

Nomination Scrutiny Procedure

One of the most important steps in making sure an election is fair and transparent is the scrutiny of nominations, as laid out in Rule 76-K of the Election Rules. The Returning Officer at the appointed hour shall take up scrutiny of nominations papers and shall examine the nomination papers and makes decisions about any objections made by any candidate, proposers, or seconders. Either on receiving such objection or on his own motion, the Returning Officer may accept or reject any nomination after conducting summary inquiry, if any, as he thinks necessary. The Returning Officer for the reasons to be recorded in writing, may reject any nomination for any number of reasons, such as nomination paper not signed or filled or candidate is disqualified under the MCS Act, Rules or Bye-laws of the Society. Minor flaws (not of a material character), such as spelling and clerical mistakes, incorrect voter list number shall not result in rejection.

The Returning Officer may permit the members in attendance to review the nomination documents during the scrutiny, ensuring openness. If any objections arise, the concerned candidate must be given a reasonable opportunity to respond within a specific timeframe. The Returning Officer records the decision on each nomination paper and communicates the reasons for rejection, if applicable.¹⁰

The candidate has the right to appeal under Section 152A of the MCS Act against the decision of rejection of his nomination within three days to the Registrar, who must resolve the appeal within ten days. There is no right of further appeal or reconsideration after the Registrar’s decision making in the appeal, and it is final.

Withdrawal in Form E-6

According to Rule 76-L, any candidate can withdraw their nomination by submitting a notice of withdrawal in writing. The notice must be subscribed by the candidate and delivered to the Returning Officer using Form E-6. This withdrawal can take place at any time after the nomination paper has been presented, but it must be done within the timeframe specified in the election program. The Returning Officer will compile a list of candidates who have withdrawn their candidature.

Candidate List Preparation

As per Rule 76-M of the Election Rules, the Returning Officer is responsible for preparing and declaring a final list of contesting candidates, which is displayed on the society’s notice board in Form E-7. The list contains the names of candidates arranged in alphabetical order. The allocation of symbols is mandatory, and the Returning Officer follows a specific procedure. Firstly, the Officer refers to the list of valid nominations, excludes withdrawn candidates, and includes candidates whose appeals have been accepted by the Registrar under Section 152A, if applicable.

A meeting is then convened to allocate symbols to the candidates. Additionally, if more than 30% of the candidates for total contesting seats come together and form a group, they can request a common symbol through a written application signed by all concerned candidates.

Polling Procedures and Guidelines

In Rule 76-N of the Election Rules, the process for conducting a poll is outlined. If the number of candidates whose nomination papers are valid exceeds the number of candidates to be elected for a particular constituency, a poll must be conducted. The Returning Officer has the authority to appoint polling officers as needed. Canvassing of votes at the election venue is prohibited. Before the poll begins, the Returning Officer must display the empty ballot box, lock it, and affix seals to prevent tampering. Each member eligible to vote receives a ballot paper with the names of candidates in alphabetical order. The voter must mark an ‘X’ against the name(s) of the candidate(s) they wish to vote for and put it into the ballot box. Members cannot enter a polling compartment when another voter is inside. If the identity of a voter is challenged, the Returning Officer will make an inquiry and decide on the matter.

If there are any interruptions or obstructions during the poll, or if it is impossible to conduct the poll, the Returning Officer has the power to postpone it and must record the reasons for doing so. The decision of postponement must be communicated to the Registrar and displayed on the society’s notice board. In case of a postponed poll, a new notice of a Special General Body Meeting must be issued at least seven days in advance11. The existing committee will continue to manage the society until the new committee is elected or an Authorized Officer is appointed by the Registrar. There is no provision for online voting for outstation members provided for in the Rules.

The Returning Officer presides over the Special General Body Meeting, which is attended by all members whose names appear in the final voter list. The meeting does not require a quorum, and the Returning Officer briefs the members about the election process.¹²

Voting rights of members of housing society

According to Section 154B-11 of the Act, no member of society shall have more than one vote in its affairs. If members of the one family own multiple flats/ houses in a society, each of them is entitle to vote as held by the Supreme Court in the case of Veena Kumari Tandon v. Neelam Bhalla & Ors. [(2007) 12 SCC 764] while interpreting Section 27 of the MCS Act (which is substantially similar to Section 154B-11 of the MCS Act) dealt with voting rights of members of all co-operative societies including housing societies (prior to the insertion of Chapter XIII-B) and upheld the principle of “one house/ unit, one vote” as provided in the statute and also held that the principle of “one family, one vote” as provided in their bye-laws was in derogation of the statute. Even those who default payments are allowed to vote. Further, every right to vote shall be exercised personally and in case of equality of votes, the chairman shall have a casting vote in the meeting of the society. Associate Members shall have a right to vote with prior consent of a Member. The provision also provides that a provisional member shall also have right to vote and in case of joint member, the person whose name stands first in the share certificate, shall have right to vote. In his absence, the person whose name stands second, and in the absence of both, the person who stands next and likewise, who is present and who is not a minor, shall have right to vote. In case of association of society, authorized person of member society shall have right to vote. In case of company or firm or any other body corporate or local authority or any legal body constituted under any law for the time being in force, the authorised director or person or any one of the partners as appointed by the firm, shall have right to vote.

Counting of votes and Declaration of results (Rule 76-O of the Election Rules)

As soon as the polling is completed according to the declared election program, the Returning Officer initiates the counting process. The Returning Officer, assisted by a Counting Assistant if appointed, opens the sealed ballot box in the presence of the members and candidates. The ballot papers are then taken out and organized into separate bundles based on the category of constituency, using different colors for easy arrangement.

Once the counting process is completed, the Returning Officer declares the constituency- wise result of the candidate who has received the highest number of valid votes as elected. The result is certified in Form E-17. Within two days of the declaration of the result, the Returning Officer submits the result to the Registrar and publishes it on the society’s notice board. The Registrar then proceeds to constitute the committee within 15 days upon receiving Form E-17.

As per Section 154B-19(4) of the MCS Act, a casual vacancy in the Committee, can be filled through co-option, and the term of the co-opted member aligns with the term of the Committee. Furthermore, as per Section 154B-22 of the MCS Act, if members from reserved categories are not available or elected to fill reserved seats, those seats are not counted towards the strength of the managing Committee for the composition of a quorum during meetings, as specified in sections 154B-20 and 154B-21 of the Act.

Election of Office Bearers

The election of office bearers is regulated by Rule 76-Q of the Election Rules. It states that the Returning Officer, must call a meeting of the elected committee members to elect the office bearers. At least seven days’ notice, given in writing with an acknowledgment, must be provided to every member of the committee. The notice should include information regarding the number of officers to be elected, as well as the date, place, and time of the meeting. The proceedings of this meeting should be recorded in the society’s minute book and communicated to the Registrar.

Moreover, as per Section 154B-19 of the MCS Act, the Committee of the society shall stand constituted on the date of declaration of result of election to the Committee by returning officer where more than two third of the Committee Members of the strength as may be decided by the Registrar, from time to time, have been elected. However, where two third is a fraction, it shall be rounded off to next higher number. The meeting will be presided over by the Returning Officer, and there is no provision of taking permission of the Registrar to call such meeting.13

Custody of Election Documents

As per Rule 76-P of the Election Rules, during an election, specific documents are required to be sealed. The Returning Officer is responsible for carefully preserving all the records of the election in a box duly locked and sealed and hand it over to the Secretary or authorized officer of the society for a period of 6 months and destroy thereafter. However, if the result of the election is disputed, the records pertaining to the election shall be preserved until the final decision of the dispute.

Election Expenditure

The Election Expenditure Report emphasizes the responsibilities of the Returning Officer in managing election expenses. The Returning Officer is required to submit statements of account that detail the expenditure incurred during the election process. However, as, there is no provision in the Election Rules on how to levy the election expenses and also due to the lack of a definite policy of the government regarding the levying of expenses, the government received various complaints that the Returning officers were charging unreasonable expenses for the elections of the co-operative housing societies. Accordingly, to resolve this issue, after taking into consideration the present situation, the maximum working hours / allowances, the government fixed the election expenses vide Government Resolution No.

dated 6/7/2022 as follows:

 

Membership strength	Returning officer and Remuneration		Election expenses		Total expenses in case of election	Total cost if unopposed
	If election held	If election unopposed	election ballot, nomination form printing and stationery	Travel expenses
1-100	3500	2000	2000	1500	7000	3500
101-250	4500	3000	2500	1500	8500	4500

As per the said GR, all the expenses incurred for holding the special general body meeting for elections such as table, chair, electricity, meeting room and other incidental expenses should be borne by the Society. Further, society must make payment to the Returning officer.

Thus, the Returning Officer must make sure that the election expenses claimed are accurate, valid, presented correctly, provided on time, and auditable by the managing committee and does not go over the cap established by the Government Resolution dated 06/07/2022. For its part, the committee is in charge of giving the returning officer all required logistical assistance and advancements. Before the subsequent General Body Meeting, the committee must submit a statement of expenses for approval.

If the Returning Officer is appointed by the Society from amongst its members then such officer is entitled to payment from the society for training expenses. The Returning Officer cannot, however, recover such costs if they are chosen from a panel.¹⁴

Election Disputes and Corrupt Practices (Rule 78 under Part XI and Rules 79 to 86 under Part XII of the Election Rules, respectively)

The rules regarding election disputes and corrupt practices are defined in Sections 78 to 86 of the Act. According to these rules, any election can only be questioned through an election petition presented to the Co-operative Court, as specified in Section 91 of the Act.

It is settled principle in law that where election process has already commenced and is at an intermediate stage, court should refrain from interfering in the same in its writ jurisdiction as the aggrieved petitioner has an efficacious alternate remedy under Section 91 of the MCS Act to challenge the same after declaration of results.15 However, in the case of Dhanraj Dattatray Patil & Ors. v. State Co-operative Elections Authority [2023 SCC OnLine Bom 776]the Bombay High Court entertained a Writ Petition filed under Article 226 challenging an order passed by the Taluka Returning Officer & Assistant Registrar, Co-operative Society, Mukhed, which deleted their names from the provisional voters list for being defaulters under sections 73(CA)(1), 75(2), and 27(10) of the MCS Act on the ground that though the Petitioner has an effective and efficacious alternate remedy under Section 91 of the MCS Act and that preparation of provisional voters list is an intermediate stage, the impugned order being patently illegal and would deprive 20 voters from participating in the elections, and directed to include the names of the Petitioners in the final voters list without disturbing the election process. While passing the order, reliance was placed on the decisions of the Dattatray Genaba Lole v. Divisional Joint Registrar, Co-operative Societies reported in (2022) 1 Bom CR 471 wherein it was held that High Court under certain circumstances alone (i.e. ground of patent illegality), can interfere with the election process.¹⁶

Corrupt practices, as defined in Section 79, include bribery, which involves candidates or their agents offering gifts or promises to induce individuals to contest or withdraw from elections, or to influence voters. Other corrupt practices involve undue influence, hiring vehicles for conveying electors, using vehicles belonging to a society for elections, incurring unauthorized expenses, making special advances or loans, and favoring electors between the declaration of the program and the declaration of election results. The Election Rules also emphasize maintaining the secrecy of voting, prohibiting officers and individuals from acting for candidates or influencing voting, canvassing near polling stations, maintaining order and decorum, and penalizing misconduct at polling stations. These rules aim to ensure the integrity and fairness of the electoral process, and any violations of these regulations may result in penalties or legal consequences.

Conclusion

On perusal and analysis of the Election Rules, particularly, Part X-IA thereof, it appears that the Government has made an endeavor to simplify the procedure of conducting the election process for small societies. However, there appears to be some lacunas like non provision of rules for situations like rejection of ballot papers (as Rule 55 is not applicable to Type “E” Societies) or not providing any rule in respect of election expenditure report or maximum that the returning officer can spend for election, etc. As this Part X-IA of the Election Rules have recently been amended, there also appears to be lack of awareness amongst the citizens and not much material on the same is easily available online including on government portals. However, active attempts are made by the co-operative department on the awareness front which is laudable.

1. Sub-section (3) of Section 154B-19 of the MCS Act
2. By Shri Rajesh Lovekar, Deputy Registrar, C.S. and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies 4, (Rajeshree Publication 2021).
3. By Shri Rajesh Lovekar, Deputy Registrar, C.S and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies 6, (Rajeshree Publication 2021).
4. Shri Rajesh Lovekar, Deputy Registrar, C.S and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies 15-19, (Rajeshree Publication 2021).
5. Shri Rajesh Lovekar, Deputy Registrar, C.S and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies, 25- 30, (RajeShree Publication 2021).
6. Shri Rajesh Lovekar, Deputy Registrar, C.S and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies 38-43, (RajeShree Publication 2021)
7. Shri Rajesh Lovekar, Deputy Registrar, C.S and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies 66-71, (RajeShree Publication 2021)
8. Rule 76-M(3)(b) of the Election Rules
9. Shri Rajesh Lovekar, Deputy Registrar, C.S and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies 80-83, (RajeShree Publication 2021).
10. Shri Rajesh Lovekar, Deputy Registrar, C.S and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies 88-91, (RajeShree Publication 2021).
11. Proviso to sub-section (4) to section 166
12. Shri Rajesh Lovekar, Deputy Registrar, C.S and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies 107-114, (RajeShree Publication 2021)
13. Shri Rajesh Lovekar, Deputy Registrar, C.S and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies 129, (RajeShree Publication 2021).
14. Shri Rajesh Lovekar, Deputy Registrar, C.S and Adv. Shreeprasad Parab, Law relating to Election of Housing Societies 133-134, (RajeShree Publication 2021).
15. Shri. Sant Sadguru Janardan Swami (Moingiri Maharaj) Shahakari Dugdha Utpadak Sanstha v. State of Maharashtra [(2001) 8 SCC 509]; Someshwar Sahakari Sakhar Limited v. Shrinivas Patil reported in 1992 SCC OnLine Bom 48 and Shri. Sant Sadguru Janardan Swami (Moingirid Maharaj) Sahakari Dugdha Utpadak Sanstha reported in (2001) 8 SCC 509
16. Also followed in Vaibhav Manohar Bhokare v. State Co-operative Election Authority through its Secretary reported in 2023 SCC OnLine Bom 133