Supreme Court settles the status of Shri Ram Mandir, Indore as a public temple: Shri Ram Mandir Indore vs. State of Madhya Pradesh (2019)

Date of the Judgment: 27 February 2019

Citation: (2019) INSC 171

Judges: R. Banumathi, J. and R. Subhash Reddy, J.

Can a temple be declared public based on the absence of evidence of private ownership and management? The Supreme Court of India addressed this question in a dispute over the status of Shri Ram Mandir in Indore. The court examined the evidence to determine if the temple was a private entity managed by a family or a public religious institution. The bench comprised Justices R. Banumathi and R. Subhash Reddy, with Justice R. Banumathi authoring the judgment.

Case Background

The case revolves around Shri Ram Mandir in Indore and a dispute over its status as a private or public temple. The appellant, Shri Ram Mandir, claimed it was a private temple managed by its Mahant, Ram Das, and his lineage. They asserted that the temple and its associated agricultural land were under their private ownership and management, passed down through a Guru Parampara (teacher-disciple tradition). The State of Madhya Pradesh, however, contended that the temple was a public one, with the land vested in the Deity and the pujaris (priests) acting merely as servants of the temple.

The dispute escalated when the State government, through an administrative order, recorded the District Collector as the manager of the temple without prior notice to the appellant. The government also initiated proceedings to lease out the temple’s lands, which the appellant challenged, claiming it was a private temple and the government had no right to interfere. The appellant sought a declaration that Shri Ram Mandir is a private temple, and an injunction to prevent the government from interfering with the management and possession of the temple’s properties.

Timeline

Course of Proceedings

The trial court initially ruled in favor of the appellant, declaring Shri Ram Mandir a private temple. It held that the entry of the Collector as manager in revenue records was without notice and not sustainable. The trial court also found no evidence that the state appointed the pujaris. The first appellate court reversed this decision, holding that the temple was public and that the land was vested in the Deity. The appellate court also stated that the Collector was rightly recorded as manager, and the pujaris were only caretakers with no rights over the land. The High Court of Madhya Pradesh upheld the first appellate court’s decision, dismissing the second appeal and affirming that Shri Ram Mandir was a public temple based on the facts and evidence presented.

Legal Framework

The judgment primarily revolves around the interpretation of evidence to determine the nature of the temple, whether it is public or private. The court examined various documents and oral testimonies to ascertain if the temple was established and managed by a private individual or family, or if it was meant for public worship. The court also considered the nature of the land grants, whether they were given to the temple itself or to the pujaris in their personal capacity. The concept of ‘Bhumiswami’ (landowner) was also central to the case, with the court examining whether the temple or the pujaris were recorded as the Bhumiswami in revenue records. The court also considered the concept of Inam lands which are lands granted by the government for specific purposes.

Arguments

Appellant’s Arguments:

• The appellant contended that Shri Ram Mandir is a private temple established by their predecessor Gurus.
• The properties were given to the temple as Inam, and Ram Das was not a mere pujari but the Mahant entitled to manage the temple and its properties.
• The entry of the Collector as Manager in the revenue records in 1975 was illegal as it was made without notice to the plaintiff.
• The appellant argued that since the temple was constructed by Shri Gulab Das, Guru Sewa Das Ji, and their Gurus, they are entitled to manage and possess the temple properties.

State’s Arguments:

• The State argued that Shri Ram Mandir is a public temple, not a private one.
• The documents show that the property is recorded in the name of the Deity, with the pujaris changing based on Guru-Disciple relationship.
• The Inam rights were conferred on the temple, not on the pujaris.
• The State contended that the appellant, Bajrang Das, was appointed as pujari by the Sub-Divisional Officer.
• The appellant participated in the auction of the temple’s land in 1985-86 and 1986-87, acknowledging the government’s control.

Issues Framed by the Supreme Court

The Supreme Court framed the following issues for consideration:

1. Whether Shri Ram Mandir is a public temple or a private temple as claimed by the appellant.
2. Whether the appellant is the Mahant of Shri Ram Mandir and whether he is in control and administration of the temple and the suit properties as claimed by him.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

Judgment

The Supreme Court held that Shri Ram Mandir is a public temple, not a private one. The court found that the appellant failed to establish that the temple was constructed with private funds or that it belonged to a particular family. The court also noted that the temple was listed as a public temple in government records and that the pujaris were appointed by the government. The court further held that the land was vested in the Deity and that the pujaris’ rights were limited to performing pooja. The court also noted that the appellant had participated in lease auctions, which indicated that they did not have ownership rights. The court also observed that the succession of pujaris was based on Guru-Shishya tradition and not hereditary, which is a characteristic of a public temple.

How each authority was viewed by the Court?

✓ State of Uttarakhand and another v. Mandir Sri Laxman Sidh Maharaj (2017) 9 SCC 579: The court followed this authority to emphasize that the necessary material pleadings ought to have been made to show how and on what basis the plaintiff claimed ownership over the temple.

✓ Goswami Shri Mahalaxmi Vahuji v. Ranchhoddas Kalidas and others (1969) 2 SCC 853: The court relied on this authority to reiterate that the origin of the temple, its management, the nature of gifts received, and the rights of devotees are relevant factors in determining whether a temple is public or private.

✓ Tilkayat Shri Govindlalji Maharaj Etc. v. State of Rajasthan and others [1964] 1 SCR 561: The court referred to this authority to highlight that public participation in the temple’s activities is an important factor in determining its public character.

✓ Sadashiv Giri and others v. Commissioner, Ujjain and others 1985 RN 371: The court followed this authority to uphold the circular dated 12.04.1974, which applied to public temples.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the lack of evidence supporting the appellant’s claim of private ownership and management of Shri Ram Mandir. The court emphasized the following points:

• Absence of Pleadings and Evidence: The appellant failed to provide sufficient pleadings or evidence regarding the construction of the temple, the source of funds, or any personal ownership by the predecessors.
• Public Listing of the Temple: The temple was listed as a public temple in government records, indicating its public character.
• Guru-Shishya Tradition: The succession of pujaris was based on the Guru-Shishya tradition, not on hereditary principles, which is a characteristic of public temples.
• Government Appointment of Pujaris: The appointment of Bajrang Das as pujari by the Sub-Divisional Officer further indicated the government’s control over the temple.
• Lease of Temple Lands: The appellant’s participation in the lease of temple lands from the government showed that they did not have ownership rights.
• Inam Rights: The Inam rights were conferred on the temple, not on the pujaris.

The court’s reasoning was thus a mix of factual analysis and legal principles, with a greater emphasis on the factual aspects of the case.

The Court considered alternative interpretations, particularly the appellant’s claim of private ownership based on Guru Parampara. However, the Court rejected this, citing the lack of evidence of private ownership and the presence of public management and control. The final decision was reached after a thorough examination of all the evidence and arguments presented by both sides.

The court’s decision was based on the following reasons:

• The appellant failed to prove that the temple was constructed with private funds.
• The temple was listed as a public temple in government records.
• The succession of pujaris was based on the Guru-Shishya tradition, not hereditary succession.
• The pujaris were appointed by the government, indicating public control.
• The appellant had leased the temple lands from the government, acknowledging government control.
• The land was bestowed on the temple for the purpose of pooja and not for the pujaris.

The court quoted the following from the judgment:

“The onus of proving that the appellant-Shri Ram Mandir falls within the description of private temple is on the appellant who is asserting that the temple is a private temple and that he is the Mahant of the temple.”

“In the case in hand, succession is admittedly governed by Guru-shishya relationship. Each pujari is not having blood relation with his predecessor pujari. When the pujariship is not hereditary, as rightly held by the High Court, Shri Ram Mandir cannot be held to be a private temple.”

“Having taken the Mandir property on lease from the Government, the appellant is estopped from denying that the temple properties are under the management and control of the Government.”

Key Takeaways

• ✓ Temples can be declared public based on the absence of evidence of private ownership and management.
• ✓ The Guru-Shishya tradition of succession is not indicative of a private temple.
• ✓ Government records and actions, such as listing a temple as public and appointing pujaris, are strong indicators of a public temple.
• ✓ Participation in lease auctions of temple land indicates that the person does not have ownership rights.
• ✓ Land bestowed on the temple is not for the personal benefit of the pujaris.

This judgment sets a precedent for determining the public or private nature of religious institutions based on evidence of ownership, management, and public participation. It emphasizes the importance of maintaining accurate records and the implications of government control over religious properties. The decision could impact similar cases involving disputes over the management and control of religious institutions.

Directions

No specific directions were given by the Supreme Court in this judgment.

Development of Law

The ratio decidendi of this case is that a temple can be declared public if there is no evidence to show that it was built with private funds or that it belongs to a particular family, especially if the succession of pujaris is based on the Guru-Shishya tradition and not hereditary principles. This case does not change the previous position of law but reinforces the existing principles for determining the public or private nature of religious institutions.

Conclusion

The Supreme Court dismissed the appeal, affirming the High Court’s decision that Shri Ram Mandir is a public temple. The court found that the appellant failed to provide sufficient evidence to support their claim of private ownership and management. The judgment reinforces the importance of evidence in determining the status of religious institutions and the rights of those who manage them.