Chartered Accountant can’t be made an Inquiry Officer u/s 24 of Societies Registration Act 1860

Chartered Accountant can’t be made an Inquiry Officer under section 24 of Societies Registration Act 1860 – High Court

In a recent judgment, Hon’ble High Court has held that appointment of Chartered Accountant Company can only be made for purpose of conducting audit and it cannot made an Inquiry Officer under section 24 of Societies Registration Act 1860.

ABCAUS Case Law Citation:
5068 (2026) (03) abcaus.in HC

In the instant case, the Petitioner had filed a complaint before the Additional Registrar raising dispute regarding election of office-bearers of the society. The Additional Registrar on the complaint of the Petitioner passed an order under provisions of Section 24 of Societies Registration Act, 1860 (the Act) appointing a Chartered Accountant Company as an inquiry officer to investigate the complaint made by the Petitioner.

Before the Hon’ble High Court, the Petitioner objected only to the appointment of a Chartered Accountant Firm as an Inquiry Officer. It was submitted that a CA can not be appointed as Inquiry Officer in terms of relevant provisions of Section 24 of the Act.

It was submitted that some independent person or a government official be appointed as Inquiry Officer. However, the Petitioner submitted that he was not against if appointed Chartered Accountant conducts an audit and submits an audit report to concerned respondents and on basis of it, an inquiry can be further conducted by independent Inquiry Officer in accordance with law.

The respondent fairly admitted that there was an ambiguity in operative part of impugned order and appointment of Chartered Accountant Company can only be made for purpose of conducting audit and it cannot made an Inquiry Officer under relevant provisions.

The Hon’ble High Court observed that a Chartered Accountant Company can not be appointed as Inquiry Officer in any circumstance, therefore, operative part of impugned order was modified to provide that the appointed CA will only conduct audit and will submit its report to concerned respondents and for purpose of appointment of an inquiry officer. 

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