Pujari of a Public Temple has no right to interfere in management of Temple Properties, Supreme Court

The Supreme Court has held that a Pujari has no right to interfere in the management and administration of a public temple built on land which is in the name of the Deity..The judgment was delivered by a Bench of Justices R Banumathi and R Subhash Reddy in an appeal filed by the Pujari of the Shri Ram Mandir, Indoukh, Madhya Pradesh..Facts.The suit property was an agricultural land allotted to Shri Ram Mandir in Inam. The land thus came to be in the possession of Shri Ram Mandir..The State of Madhya Pradesh, the respondent in the case, recorded the name of the District Collector as one of the managers of the Temple through an administrative order without informing the appellant. The State also initiated the process of auctioning the suit property..The case of the appellant, who was the Pujari at the temple, was that the temple was private property. It was the appellant’s argument that the management of the temple was vested with the Pujari who had been performing the rituals at the temple since the time of his guru. It was his contention that the succession of the rights and duties regarding management of the temple falls upon descendants as per the rules of Guru Parampara..The appellant, therefore, claimed that the Government has no right to interfere in the functioning and administration of the temple since it is a private temple..It was also highlighted by the Appellant that the Government has not given any aid towards maintenance, management or repairs of the temple. The appellant thus sought a permanent injunction to restrain the Respondents from interfering in the possession of the temple property. A declaration was also sought to assert that the temple is private property and the government has no rights on the same..The Respondents, however, contended that the land belonged to the Shri Ram Mandir and the Appellant’s role is that of a Pujari appointed by the Government. This status, the Respondents claimed, makes the Pujari a servant of the temple and does not give him the rights of an owner. The inclusion of the District Collector’s name in the revenue records was in accordance with the Law, the Respondents claimed..Trial Court’s ruling and the First and Second Appeals.The Trial Court, upon examination of oral and documentary evidence, held that the temple is private property and not a public temple. The Trial Court held that the entry of the District Collector’s name without notice cannot be sustained. The court found no evidence to back the government’s claim that the pujari was appointed by the government..The State government appealed to the First Appellate Court which allowed the appeal and ruled that the temple is a public temple. The Appellate Court observed that the Inam lands of the temple and the title in the disputed land vests with the deity. The Appellate Court further held that the Collector was rightly appointed the manager and the pujari only has the right to perform rituals and does not have right over the suit land..A second appeal was preferred by the appellant wherein the High Court upheld the finding of the First Appellate Court and dismissed the second appeal..Supreme Court Judgment.The Appellant was represented by Advocate Puneet Jain while the Respondent State was represented by Advocate Vaibhav Srivastava..The Court examined whether the temple is a public temple or private temple and whether the Appellant is in control and administration of the temple..The Court noted various aspects in this regard. It observed that there was no blood relationship between the successive pujaris..If the temple was a private temple, the succession would have been hereditary and would have been governed by the principles of Hindu succession i.e. by blood, marriage and adoption, the Court said..In the case in hand, the succession was 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“, the Court concluded..The Court also placed extensive reliance on the judgment of the First Appellate Court. The First Appellate Court had referred to various documents, in particular pattas and held that all the lands have been given to the Shri Ram Mandir Devsthan by way of Inam. .The documents showed that the lands are Inam lands of Shri Ram Mandir and that the status of Ram Das and Bajrang Das were only of pujaris..The Court also proceeded to dissect the status of the appellant with respect to the temple as a lessee. Plaintiff Ram Das himself got the land in the year 1985-86 on lease for Rs.860/- from the Government, the Court noted..“An amount of Rs.600/- was deposited on 31.07.1986. Thereafter, in the year 1986-87, pujari Ram Das got the lease renewed for one year at Rs.860/- out of which he has deposited Rs.460/- in 1987 for which a receipt was issued to pujari Ram Das..“The fact that the appellant having taken the Mandir lands on lease from the Government clearly shows that the properties were never owned by the pujaris in their individual capacity”, the Bench held..The Court, therefore, made it clear that 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..“The suit lands have been given in the name of Shri Ram Mandir and few other lands in the name of Ganesh Mandir for the arrangement of pooja, archana, naivedya, etc. for the public temple and the pujari has no right to interfere in the management of these lands as his status is only that of pujari”.The Court, thus, dismissed the appeal finding no infirmity in the rulings of the High Court..Read the Judgment: