Unit Prasad Singh v. State of Jharkhand

This case clarifies a simple rule: the Registrar of Trade Unions has an administrative job. The Registrar cannot judge whether a union election was legal or order a fresh election. If office-bearer legitimacy is disputed, the parties must go to a civil court.

• Core idea: Election disputes → civil suits, not Registrar orders.
• Outcome: Registrar’s order cancelling the 2003 election and directing a re-poll was set aside; appeal dismissed.

• What powers does the Registrar have to decide rival union election grievances?
• Can the Registrar invalidate an election and order a fresh one?

• The Trade Unions Act, 1926 does not give the Registrar power to decide election legality or propriety.
• Disputes about who the lawful office-bearers are must be decided by a competent civil court.
• The Registrar’s functions are administrative, not quasi-judicial.

Under the Trade Unions Act, the Registrar is an administrative authority. He cannot act as a quasi-judicial body to decide election disputes or order re-polls; such questions belong to civil courts.

• Draws a clean line between administration (Registrar) and adjudication (courts).
• Prevents executive overreach in internal union elections.
• Gives unions and members a clear forum for remedy—civil suits.

1. Registrar cannot judge union election validity.
2. Registrar cannot order fresh elections.
3. Election disputes → civil court jurisdiction.

Mnemonic: “R-A-C” — Registrar = Admin only; Courts decide elections.

1. Identify: Is it an election dispute? → Court.
2. Limit: Registrar records names/returns—nothing more.
3. Proceed: File civil suit for adjudication.

Registrar (Trade Unions)

Authority that registers unions and records office-bearers; functions are administrative.

Quasi-judicial

Power to adjudicate disputes like a court; not vested in the Registrar for elections.

Civil Suit

Proceeding in a civil court for rights and liabilities between parties.