Introduction:
The present case, M/S Nirmal Ujjwal Credit Co-operative Society Ltd. v. Ravi Sethia & Ors., brought before the Supreme Court of India, raised a significant question concerning the permissible scope of investments by a Multi-State Co-operative Society (MSCS) under the Multi-State Co-operative Societies Act, 2002. The Appellant, a credit co-operative society registered under the Act, had submitted a resolution plan for a textile company undergoing insolvency proceedings. This plan, however, was rejected by the National Company Law Appellate Tribunal (NCLAT) on the ground that such an investment violated Section 64(d) of the Act, which restricts MSCS entities from investing in businesses outside their “same line of…

