Sugathaananada Thera vs. Ajith Bodinagoda and Others – sllr 2006 volume 3 page 315

In the dispute between the officials of the Wellawatta YMBA (alleged trustees and officials of the unregistered society) and the Venerable U. M. Sugathananda Thero with others, the court addressed the maintainability of an action by officials of an unincorporated association, and the validity of a purported trust over the disputed land. It was determined that proceedings initiated without compliance with Section 16 of the Civil Procedure Code were not maintainable, and that the plaintiffs failed to demonstrate the existence of a valid notarially executed trust as required by Section 5(1) of the Trust Ordinance. The findings emphasized that unregistered societies lack juristic personality and cannot sue in their own name absent statutory authority or compliance with procedural requirements.