S H Firdous and 02 others vs Mr. Laxman Hulugalle and 7 others – CA WRIT NO.259/2012-2013

The case between S. H. Firdous and two others (trustees of the Community Trust Fund) and Mr. Laxman Hulugalle (Director General, National Secretariat for Non-Governmental Organizations) and others involved judicial review of the lawfulness of appointing an interim board of management to administer the Community Trust Fund. The court determined that the appointment, made by the Minister under Section 14A of the Voluntary Social Services Organization (Registration and Supervision) Act No. 31 of 1980 (as amended), was ultra vires as it preempted the required process—specifically, the mandatory submission and consideration of the final report by the board of inquiry. The legal principle reaffirmed is that administrative powers must be exercised strictly in accordance with statutory preconditio