Section 92 CPC maintainable for Societies: Operation Asha v. Shelly Batra

Section 92 of the CPC is maintainable and applies to public trusts and constructive trusts. In Operation Asha vs. Shelly Batra, a non-profit society that works for disadvantaged communities, the Apex Court found that the Doctrine of Constructive Trust applies even if societies are registered under the Societies Registration Act, 1860 as long as some fiduciary criteria are met.

The aim and objective of Operation Asha is of public and charitable nature. All the incomes, earnings, properties and MoAs are to be solely dedicated to promote the society’s aims. Furthermore, the strict “non-profit” rule of the society determines the society to have a credible fiduciary relationship in this scenario. 

A bench of Justices J B Pardiwala and R Mahadevan reaffirmed the English principle of constructive trusts for application in Indian courts too. The codification of the constructive trust principles was to limit judicial discretion but it does not mean that the doctrine has been removed from Indian law. The 2019 judgment in Janardan Dagdu Khomane and Another v. Eknath Bhiku Yadav & Ors. had elaborated upon this concept. 

The repeal of Section 94 of the Trusts Act, 1882 by Benami Transactions Prohibition Act, 1988 does not prevent the Court from declaring a trust outside the scope of this Act. In Sugra Bibi v. Hazi Kummu Mia (1968), the Court stressed on the dominant purpose of the plaint which must be in furtherance of public interest. Section 92 suits need to be motivated from representative capacity to vindicate public rights and not merely individual interests. 

The serious allegations of mismanagement and financial misconduct affecting the public interest may be pursued under Section 92 because it is a special provision. However, personal grievances need to be addressed separately. Even if certain private rights are agitated, it does not take away the importance of the other allegations.

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Legal Internship for Undergraduate Law Students in Delhi at Relan’s Legal

At Relan’s Legal, interns won’t just observe from the sidelines. They will actively participate in legal drafting, preparing documents like notices, applications, and replies under supervision. You’ll also conduct structured research on legal propositions, case laws, and statutes, contributing meaningfully to ongoing matters.

This legal internship for undergraduate law students in Delhi is structured to help law students build professional ethics, develop core skills, and understand practical procedures through real-time tasks and mentorship.

Primary Work Areas

Selected interns will be actively involved in:

  • Legal Drafting – including pleadings, notices, and written submissions
  • Legal Research – involving judgments, statutory interpretation, and case study reviews

The focus will be on hands-on learning and practical legal skill-building, not just observation or theoretical reading. Interns will work closely under the guidance of professionals to understand how legal arguments are structured and supported in practice.

Office Location

The internship will be conducted on-site at the firm’s office in:

Green Park, South Delhi
A well-connected and safe legal hub in the heart of Delhi, easily accessible by metro and public transport.

Eligibility Criteria

This legal internship for undergraduate law students in Delhi is open to law students who meet the following conditions:

  • Must be currently pursuing a law degree (BA LLB, BBA LLB, LLB, etc.)
  • Should be proficient in both English and Hindi
  • Age bracket: 18 to 23 years
  • Must have access to a personal laptop, as interns are expected to work on their own systems

Working Hours

Relan’s Legal offers a healthy work-life balance, maintaining:

Fixed Working Hours: 10:00 AM to 6:00 PM
This structure ensures productivity without burnout, creating a stress-free and professional atmosphere ideal for learning.

Perks and Benefits

Here are some of the key perks associated with this legal internship opportunity:

  • Stress-Free Work Environment – with a culture of learning, mentorship, and clarity
  • Fixed Working Hours – no long or undefined office stays
  • Experience Certificate – acknowledging your contribution and learning
  • Letter of Recommendation – awarded to high-performing interns
  • Stipend – provided in the form of transport allowances, to support daily commuting

This makes it an ideal opportunity for undergraduate law students residing in or near Delhi NCR.

Who Should Apply?

This internship is best suited for law students who:

  • Want to explore core legal research and drafting work, gaining real-time exposure to legal documentation, statutory interpretation, and legal reasoning
  • Are based in or around Delhi NCR and can commute daily to Green Park without logistical constraints or prefer on-site learning over remote internships
  • Wish to build a long-term career in litigation, corporate law, or general legal practice, and are looking for foundational courtroom skills and drafting experience
  • Are seeking practical legal training under a supportive and professional legal team that encourages continuous learning, ethical conduct, and performance-driven growth

Application Process

Interested candidates must submit the following:

  • A brief cover letter expressing their interest and goals
  • An updated CV outlining academic background and skills

Email your application to:
hiringadvvrelan@gmail.com

Early applications are encouraged as positions are limited. Make sure your cover letter reflects your interest in practical legal work, your availability, and your willingness to commit to an on-site internship.

Conclusion

Whether you’re a first-year student eager to explore the legal world or a senior law student looking to refine your drafting and research skills, this legal internship for undergraduate law students in Delhi at Relan’s Legal offers the perfect blend of professionalism, structured mentorship, and meaningful practical exposure across real-world legal matters.

Take the first step toward your legal career by gaining the core skills that truly matter in today’s competitive legal industry. Apply today and become part of a law office that believes in structured learning, growth through hands-on experience, and performance-based development.


Also Read – Paid Legal Internship in Mumbai at Goenka Law Associates!

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