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Adv. Tamanna ShaikhAdvocate · Malad West, Mumbai
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What Is a Section 22 Change Report?

Whenever something in the Public Trust Register changes — a trustee dies, resigns or is appointed, the trust buys or sells immovable property, or its name or objects are altered — the trust is…

Last updated 28 October 20263 min readBy Adv. Tamanna Shaikh, Advocate, MAH/5287/2023

मराठीत वाचा

Illustration of an advocate reviewing a trust register at a teak desk with a stamp, stapler and plant

Whenever something in the Public Trust Register changes — a trustee dies, resigns or is appointed, the trust buys or sells immovable property, or its name or objects are altered — the trust is generally required to report that change to the Charity Commissioner. This report is called a change report, and it is filed under Section 22 of the Maharashtra Public Trusts Act, 1950.

Key facts

What it is
How a trust reports changes to its entries in the Public Trust Register (Section 22)
Deadline
Ordinarily within 90 days of the change
Examples
Trustee changes, property dealings, name or address changes, changes to objects
Filed with
The Deputy or Assistant Charity Commissioner, usually through the trust’s portal login
Late?
File with a request to condone the delay

Why it exists

The Public Trust Register is meant to be a current, reliable record of who is actually managing a trust and what it owns. A change report is what keeps that register accurate as trustees come and go and property is bought and sold.

What triggers one

  • Death, resignation or appointment of a trustee
  • Acquisition or disposal of immovable property
  • A change in the name or registered address of the trust
  • An alteration to the objects of the trust

What happens after filing

The Deputy or Assistant Charity Commissioner conducts an enquiry into the change reported, and once satisfied, varies the entries in the Public Trust Register accordingly.

What happens if it is not filed

The trust continues to exist, but its official record does not reflect reality. In practice this surfaces later — a bank refusing to act on a resolution passed by trustees who are not on record, or a sale that cannot be completed because the register still names a trustee who has since died. A change report can still be filed late, with an explanation for the delay.

Who files and who decides

The trustees of the registered public trust file the report, usually through the trust’s login on the Charity Commissioner’s portal, with the supporting papers. The Deputy or Assistant Charity Commissioner who has jurisdiction over the trust examines the report and, where required, holds an inquiry before the change is entered in the register.

Examples of when a change report is needed

  • A trustee resigns, dies or is replaced, or a new trustee is appointed
  • The trust moves its office to a new address
  • The trust buys or receives immovable property, or its property is disposed of with sanction
  • The trust amends its deed, within what the deed permits

Frequently asked questions

Is a change effective only after the change report is accepted?

The change takes place when the trust makes it in accordance with its deed, but it is the accepted change report that updates the public register, and banks, property registries and courts rely on the register.

What if more than 90 days have passed?

The report can still be filed with a request to condone the delay, explaining the reasons.

Is a change report needed when the trust has no property or bank account?

Yes. The duty is to report changes in the entries of the register, whatever the size of the trust.

See also: Changing the name or objects of a trust.

Free download: Change report checklist (Section 22) (PDF) · all free formats

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This page describes general procedure and does not constitute legal advice. What applies to a particular matter depends on its own facts.

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