Madras High Court Upholds Writ Court's Directions in Temple Administration Dispute

Court affirms role of HR & CE Department in maintaining temple administration and peace, while allowing civil court recourse for trusteeship disputes.

In a significant ruling, the Madras High Court has upheld the directions issued by the Writ Court in a dispute concerning the administration of the Arul Migu Vembiamman Thirukovil Trust, a temple located on grama-natham land, which has been classified as a public religious institution. The decision, delivered by Justices S.M. Subramaniam and P. Dhanabal, emphasizes the Tamil Nadu Hindu Religious and Charitable Endowments (HR & CE) Department's authority to intervene in cases of maladministration while safeguarding the customary religious practices.

The case arose when Mr. R. Thennarasu, the writ petitioner, sought intervention against the interference by Mr. R. Thirumurugan, the appellant and the fourth respondent in the writ petition, in the temple's day-to-day affairs. The Writ Court had previously granted interim relief to Mr. Thennarasu, allowing him to continue as the Hereditary Trustee and restraining Mr. Thirumurugan from interference. This prompted the intra-court appeal by Mr. Thirumurugan.

The High Court's judgment clarifies the temple's status as a public religious institution, based on the Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959. The court highlighted that the temple, situated on public land and supported by village contributions, meets the criteria outlined in Section 6(20) of the Act, which defines a temple as a place of public religious worship dedicated to the community.

The judgment underscores the HR & CE Department's jurisdiction to ensure proper temple management and address any maladministration or misappropriation of funds, as detailed in Section 63 of the Act. While the department is empowered to enforce administrative corrections, it must not interfere with the temple's religious customs and practices.

The court also addressed the appellant's contention that the Writ Court exceeded its mandate by issuing directions beyond the original prayer. It upheld the Writ Court's authority under Article 226 of the Indian Constitution to expand relief in the interest of justice, emphasizing that judicial review is not restricted to the relief sought in the writ proceedings.

Furthermore, the court acknowledged the pending application filed by Mr. Thennarasu under Section 63(B) of the Act, directing the Joint Commissioner to adjudicate the matter on its merits. It also advised parties to approach the civil court to resolve private disputes over trusteeship.

The judgment serves as a critical precedent in delineating the roles and responsibilities of religious and administrative bodies in temple governance, balancing state intervention with respect for religious customs.

Bottom Line:

Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959 - Dispute regarding the administration of a temple classified as a public religious institution - Writ Court's power to mould relief and grant directions in the interest of justice.

Statutory provision(s): Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959 Sections 6(16), 6(18), 6(20), 63, 63(B); Constitution of India, 1950 Article 226

R.Thirumurugan v. R.Thennarasu, (Madras)(DB) : Law Finder Doc Id # 2819484