Jamalpur Arya Samaj v Dr. D. Ram
Rule established
Office in a private religious body is not a public office; quo warranto does not lie.
Facts
- Dispute arose over occupancy of an office within the Jamalpur Arya Samaj
- Arya Samaj is a private religious organisation, not created or regulated by statute
- Quo warranto was sought against the person holding the disputed office
Issue
- Does quo warranto lie against the holder of an office in a private religious organisation?
Held
- Quo warranto does not lie. The Arya Samaj is not a statutory body; the office is not a public office created or regulated by statute.
Ratio Decidendi
Quo warranto requires a public office created or regulated by statute carrying public duties. A private organisation does not confer public offices amenable to quo warranto challenge.
How to use it in an exam
Negative illustration for ADM-5.4. Pair with University of Mysore v Govinda Rao to define public office through contrast.
Source
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.