Bombay High Court Upholds Member's Expulsion From Mumbai Press Club For Facilitating Meeting Of Bhima-Koregaon Accused
The Bombay High Court has refused to stay the expulsion of a member from the Mumbai Press Club, holding that it is the prerogative of the Club to determine what conduct brings the institution into disrepute. The Court observed that where the Managing Committee has acted within its jurisdiction and followed the procedure prescribed by the Club's bye-laws, the Court cannot substitute its...
The Bombay High Court has refused to stay the expulsion of a member from the Mumbai Press Club, holding that it is the prerogative of the Club to determine what conduct brings the institution into disrepute. The Court observed that where the Managing Committee has acted within its jurisdiction and followed the procedure prescribed by the Club's bye-laws, the Court cannot substitute its own opinion for that of the Club on whether a member's conduct is disreputable.
Justice Prafulla S. Khubalkar was hearing an interim application filed in an appeal challenging the order of the Bombay City Civil Court refusing to stay the expulsion of the applicant from the Mumbai Press Club. The applicant had been expelled from the Club for six years following disciplinary proceedings arising out of a meeting held at the Club on 19 January 2026, which he had organised along with two other members and in which four accused in the Bhima-Koregaon case had participated. The Enquiry Committee concluded that the applicant had facilitated the meeting, which could have resulted in a violation of the bail conditions of the accused and caused disrepute to the Club. Acting on the report, the Managing Committee resolved to expel the applicant. The applicant contended that the enquiry was conducted in violation of the principles of natural justice as the documents sought by him, including the minutes of the meeting, were not supplied.
The Court noted that, prima facie, the procedure prescribed under Article 11 of the bye-laws had been followed. It observed that the Managing Committee had considered the applicant's explanation, constituted a fact-finding committee, considered its report and thereafter passed the resolution of expulsion.
Rejecting the contention of breach of natural justice, the Court observed that the applicant had been served with a show-cause notice, had submitted detailed replies and had participated in the enquiry proceedings, which he was even permitted to audio-record. It noted that disciplinary proceedings conducted by a private club are not required to conform to the standards applicable to judicial proceedings and that substantial compliance with the principles of natural justice would suffice.
The Court further observed that it was undisputed that the applicant had facilitated the meeting of persons accused in the Bhima-Koregaon case and noted that the National Investigation Agency had sought cancellation of their bail on the ground that the meeting violated the bail conditions. It held that such conduct could legitimately be viewed as bringing the Club into disrepute.
The Court remarked that it is the prerogative of the Club to decide which conduct falls within that category, and the Courts cannot substitute their opinion for the decision of the Managing Committee in that regard.
“… the conduct on the part of the applicant in facilitating the meeting of accused persons can surely be viewed as an act which has brought the Club into disrepute. In any case, it is prerogative of the Club to decide as to which particular conduct can fall within this category and the Courts cannot substitute their opinion over the decision of the Club in that regard,” the
Holding that the Trial Court's refusal to grant interim relief was a plausible exercise of discretion and that no perversity warranting appellate interference was made out, the Court rejected the interim application.
Case Title: Gurbir Singh v. Samar Mohammed Khadas [Interim Application No. 4946 of 2026 in Appeal From Order No. 685 of 2026].