Gokarna Temple Administration: Supreme Court Orders Interim Committee in Ramachandrapura Math vs. Sri Samsthana Mahabaleshwara Devaru (2021)

Introduction

Date of the Judgment: April 19, 2021

Citation: (2021) INSC 217

Judges: S. A. Bobde, CJI., A.S. Bopanna J., V. Ramasubramanian J.

Who has the right to manage a historic temple—a religious math or a government-appointed body? The Supreme Court of India addressed this complex question in a case involving the Gokarna Mahabaleshwara Temple. This case revolves around a dispute over the temple’s administration, with the Ramachandrapura Math claiming ownership and the state government asserting its regulatory authority under the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997. The Supreme Court, acknowledging the need for a balanced approach, ordered an interim arrangement to manage the temple. The bench comprised of Chief Justice S. A. Bobde and Justices A.S. Bopanna and V. Ramasubramanian.

Case Background

The dispute centers on the Gokarna Mahabaleshwara Temple, which was included in a notification issued on April 30, 2003/May 1, 2003, under Section 23 of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997. This notification brought the temple under the purview of the Act. The Ramachandrapura Math, claiming that the temple was attached to their Mutt and thus exempt under Section 1(4) of the Act, sought its removal from the notification. Consequently, on August 12, 2008, the government ordered the temple’s de-notification and directed its administration to be handed over to the Math. This order was challenged by devotees and former trustees, leading to a legal battle.

Timeline

Course of Proceedings

The High Court of Karnataka, upon hearing the writ petitions challenging the de-notification order of August 12, 2008, quashed the said order. The High Court held that the temple remained a notified temple under the Act of 1997. It determined that the question of whether the temple belonged to the ‘Mutt’ needed to be decided by a competent Civil Court, as disputed questions of fact could not be resolved in a writ petition. The High Court also constituted an “Overseeing Committee,” headed by the Deputy Commissioner of Uttara Kannada District, with a former judge of the Supreme Court as an advisor, to manage the temple until a committee was formed under the Act of 1997.

Legal Framework

The case primarily involves the interpretation of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997. Specifically, Section 23 of the Act allows the government to notify temples under its purview. Section 1(4) of the Act stipulates that the Act does not apply to temples belonging to a Mutt.

The relevant provisions are:

• Section 23 of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997: This section empowers the government to issue notifications bringing religious institutions under the purview of the Act.
• Section 1(4) of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997: This section states that the Act shall not apply to temples that belong to a Mutt.

Arguments

The Ramachandrapura Math argued that the Gokarna Mahabaleshwara Temple has historically been under their administration, dating back to the 8th century A.D. They contended that the temple was established by Adi Shankaracharya and has been managed by the Mutt’s pontiffs. They cited Section 1(4) of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997, which exempts temples belonging to a Mutt from the Act’s purview. The Math also argued that the government order of August 12, 2008, which de-notified the temple, was based on a proper inquiry, and the temple should be under their control.

The contesting respondents, representing devotees and former trustees, argued that the temple was rightly notified under the Act of 1997. They disputed the Math’s claim of ownership and highlighted that the temple had been managed by the authorities under the Act since 2003, until the de-notification order. They supported the High Court’s decision to quash the de-notification order and to constitute an Overseeing Committee.

The State of Karnataka, while initially supporting the de-notification, later argued for an interim arrangement to protect the interests of all parties, considering the ongoing dispute.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame specific issues in this order. However, the core issue before the court was to determine an appropriate interim arrangement for the administration of the Gokarna Mahabaleshwara Temple, given the ongoing dispute regarding its ownership and the applicability of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Supreme Court did not cite any specific cases or books in this interim order. However, the Court did refer to the following legal provisions:

• Section 23 of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997: This provision was the basis for the initial notification that brought the temple under the Act’s purview.
• Section 1(4) of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997: This provision was the basis of the Math’s claim that the Act did not apply to the temple.
• Section 20-A of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997: This provision, introduced in 2012, assigns the decision on disputed questions of the present nature to the ‘Rajya Dharmika Parishad.’

Judgment

The Supreme Court, while granting leave to appeal, decided to modify the interim arrangement for the administration of the Gokarna Mahabaleshwara Temple. The Court noted that the High Court had already quashed the government order that de-notified the temple. The Court also observed that the factual determination of whether the temple belongs to the Math requires detailed consideration, including the validity of the Act of 1997, which is pending in another case.

The Court decided to continue the “Overseeing Committee” constituted by the High Court but modified its composition. The committee was placed under the chairmanship of Hon’ble Justice Sri. B.N. Srikrishna, a former Judge of the Supreme Court of India. The other members include the Deputy Commissioner, Superintendent of Police, and Assistant Commissioner of Uttara Kannada District, two eminent persons nominated by the State Government, and two Upadivantas of the Gokarna Temple nominated by the Deputy Commissioner in consultation with the State Government.

The Court directed the Ramachandrapura Math to hand over the charge of the temple to the Assistant Commissioner, who would act as the Secretary to the Overseeing Committee. The committee was tasked with overseeing the functioning of the temple, adhering to all traditions, until a final determination is made in the appeals.

The authorities were viewed as follows:

✓ Section 23 of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997: The Court acknowledged the notification under this section as the basis for the temple’s initial inclusion under the Act.

✓ Section 1(4) of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997: The Court recognized this section as the basis for the Math’s claim of exemption.

✓ Section 20-A of the Karnataka Hindu Religious Institutions and Charitable Endowments Act, 1997: The Court noted that this provision assigns the decision on disputed questions to the ‘Rajya Dharmika Parishad’.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily driven by the need to maintain a balanced approach during the pendency of the appeals. The Court was mindful of the fact that the High Court had quashed the de-notification order, thereby restoring the temple’s status as a notified institution under the Act of 1997. However, it also recognized the Ramachandrapura Math’s claim of historical ownership and the need for a detailed factual determination of this claim. The Court emphasized that the initial proceedings to de-notify the temple were unilateral and did not involve the contesting respondents, which further necessitated an interim arrangement to protect all parties’ interests.

The Court’s reasoning was a blend of factual considerations (the historical claims of the Math and the procedural irregularities in the de-notification process) and legal considerations (the provisions of the Act of 1997 and the High Court’s order). This is reflected in the ratio of fact to law.

The Court considered that a final decision could not be made without a detailed examination of the factual and legal aspects. The Court also noted that the Tehsildar’s recommendation to entrust the administration of the temple to the Mutt was based on the opinion of the President of Gram Panchayat, which was insufficient to satisfy the requirements of Section 1(4) of the Act of 1997.

The Court stated, “From the rival contentions what is relevant ultimately is to consider whether the factual aspect relating to the status of the temple i.e. whether it belongs to the ‘Mutt’ has been established in accordance with the requirement under law to establish the factual position.”

The Court also observed, “The Tehsildar, on the other hand, has based the conclusion to recommend the entrustment of the administration of the temple to the ‘Mutt’ in view of the overall improvement and also the opinion expressed by the President of Gram Panchayat, Gokarna which would not be sufficient to satisfy the requirement of Section 1(4) of Act, 1997.”

The Supreme Court also emphasized, “In a matter where rival contentions are being urged by the appellants and the contesting respondents relating to the status of the temple, appropriate determination/adjudication is required to be made in accordance with law after providing opportunity to both.”

Key Takeaways

✓ The Supreme Court did not make a final determination on the ownership of the Gokarna Mahabaleshwara Temple.

✓ An interim “Overseeing Committee,” headed by a former Supreme Court judge, was constituted to manage the temple.

✓ The Court emphasized the need for a detailed factual determination of the temple’s status.

✓ The decision highlights the importance of procedural fairness and balanced approach in resolving disputes related to religious institutions.

Directions

The Supreme Court directed the following:

• The “Overseeing Committee” shall function under the Chairmanship of Hon’ble Justice Sri. B.N. Srikrishna.
• The committee shall manage the affairs of the temple in all respects.
• The Ramachandrapura Math shall hand over the charge of the temple to the Assistant Commissioner.
• The committee shall adhere to all traditions.
• The nomination of two eminent persons and two Upadivantas shall be completed within 15 days.

Development of Law

The ratio decidendi of this case is that in disputes concerning the administration of religious institutions, especially where factual claims of ownership are contested, an interim arrangement is necessary to protect the interests of all parties. The Supreme Court’s decision emphasizes the need for a balanced approach and procedural fairness in such cases. This decision does not change the previous positions of law, but it clarifies the need for a balanced approach in cases where the factual aspects are disputed.

Conclusion

The Supreme Court’s interim order in the Ramachandrapura Math vs. Sri Samsthana Mahabaleshwara Devaru case reflects a careful balancing of competing interests. By establishing an independent committee to oversee the administration of the Gokarna Mahabaleshwara Temple, the Court ensured that the temple’s affairs are managed appropriately pending a final determination of the ownership dispute. This decision underscores the importance of procedural fairness and the need for detailed factual inquiries in matters concerning religious institutions.