A) ABSTRACT / HEADNOTE

The landmark case Mahant Moti Das v. S.P. Sahi (1959 Supp. (2) SCR 563) represents a significant judicial affirmation of the constitutional validity of state-led statutory interventions in religious trust management. It addressed a constitutional challenge to the Bihar Hindu Religious Trusts Act, 1950, particularly regarding its alleged infringement of fundamental rights enshrined in Articles 14, 19(1)(f), 25, 26, and 27 of the Constitution of India. The petitioners, religious heads (Mahants) of Hindu maths (monasteries) and temples, contended that the Act imposed arbitrary classifications, excessive interference with religious administration, unauthorized taxation, and infringed on religious autonomy.

The Supreme Court, through Justice S.K. Das, upheld the Act’s validity by applying the doctrine of reasonable classification and public interest regulation of trust property. The Court ruled that legislative classification distinguishing between Hindu, Jain, and Sikh trusts was constitutionally permissible under Article 14. Further, the restrictions on property rights were held to be reasonable under Article 19(5), and administrative oversight by the State did not amount to interference with religious practice under Articles 25 and 26. Additionally, the Court validated the imposition under Section 70 of the Act as a regulatory fee and not a tax, distinguishing it from Article 27’s prohibition on religious taxation.

This decision reinforced the State’s supervisory role over religious endowments while balancing the rights of religious denominations to manage internal religious affairs. It established a constitutional blueprint for future state legislations aiming to regulate and reform religious trusts, setting precedent on legislative competence and fundamental rights interpretation.

Keywords: Bihar Hindu Religious Trusts Act, Mahant, Religious Trusts, Fundamental Rights, Constitutionality, Article 14, Article 25, Religious Denomination

B) CASE DETAILS

i) Judgement Cause Title:
Mahant Moti Das v. S.P. Sahi, Special Officer in charge of Hindu Religious Trusts & Others

ii) Case Number:
Civil Appeals Nos. 225, 226, 228, 229, and 248 of 1955

iii) Judgement Date:
April 15, 1959

iv) Court:
Supreme Court of India

v) Quorum:
S.R. Das, C.J., S.K. Das, P.B. Gajendragadkar, K.N. Wanchoo, M. Hidayatullah, JJ.

vi) Author:
Justice S.K. Das

vii) Citation:
[1959] Supp. (2) SCR 563

viii) Legal Provisions Involved:
Bihar Hindu Religious Trusts Act, 1950: Sections 2, 5–8, 28, 32, 55(2), 60, 70
Constitution of India: Articles 14, 19(1)(f), 19(5), 25, 26, 27, 133

ix) Judgments overruled by the Case (if any):
None reported.

x) Case is Related to which Law Subjects:
Constitutional Law, Religious & Charitable Trusts Law, Administrative Law

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

This batch of appeals emerged against the backdrop of the post-independence legislative attempts by the State of Bihar to regulate religious endowments through the Bihar Hindu Religious Trusts Act, 1950. The appellants, religious leaders managing various Hindu religious institutions, challenged the Act on grounds of constitutional invalidity. They argued that it arbitrarily excluded Sikh institutions, interfered with religious freedom, and imposed unjust financial levies. The Act had been passed with Presidential assent and intended to regulate Hindu religious trusts for better administration and preservation of trust properties. The challenge touched upon the limits of state interference in religious affairs and interpretation of fundamental rights under the Indian Constitution.

D) FACTS OF THE CASE

The appellants were Mahants and Shebaits managing religious maths and temples across Bihar. They received notices under Section 59 of the Bihar Hindu Religious Trusts Act, 1950, asking them to furnish statements of properties under their control. In response, they filed writ petitions and suits in the Patna High Court under Articles 226 and 227, arguing that their institutions were either private in character or that the Act violated their fundamental rights.

Their key contentions included:

• Unequal treatment between Hindu, Jain, and Sikh religious trusts under Sections 2, 5, 6, 7, and 8, violating Article 14.

• Infringement on their property rights under Article 19(1)(f) through administrative interference by the Board established under the Act.

• Encroachment on their religious freedoms and internal management rights under Articles 25 and 26.

• Imposition of an unauthorized fee under Section 70, akin to taxation, violating Article 27.

• Violation of appellate rights under Article 133 due to Section 55(2) of the Act.

E) LEGAL ISSUES RAISED

i) Whether the Bihar Hindu Religious Trusts Act, 1950 violates Article 14 by unequally treating Sikh, Hindu, and Jain trusts.

ii) Whether the Act violates Article 19(1)(f) by infringing upon trustees’ rights to manage and enjoy trust properties.

iii) Whether Articles 25 and 26 are violated due to the State’s interference in religious administration and practices.

iv) Whether the fee levied under Section 70 is an unauthorized tax, violating Article 27.

v) Whether Section 55(2) overrides Article 133 and unlawfully limits the right of appeal.

F) PETITIONER/ APPELLANT’S ARGUMENTS

i) The counsels for Petitioner / Appellant submitted that Sections 2, 5, 6, 7, and 8 of the Act contravened Article 14 by excluding Sikh trusts and making separate provisions for Jain sects, thus treating similarly situated religious trusts unequally.

ii) They argued that Chapters V, Sections 28 and 32, drastically curbed the managerial rights of Mahants and Shebaits, reducing them to functionaries under the Board and violating their proprietary rights under Article 19(1)(f).

iii) They contended that administrative directions affecting budgets and worship routines, including Section 60, infringed upon religious freedom protected under Articles 25 and 26.

iv) They submitted that the five percent fee levied on trust income under Section 70 was effectively a tax without parliamentary sanction, violating Article 27.

v) They claimed that Section 55(2), which barred appeals from the High Court’s decision, violated the appellate jurisdiction conferred by Article 133 of the Constitution.

G) RESPONDENT’S ARGUMENTS

i) The counsels for Respondent submitted that classification among Hindu, Jain, and Sikh religious trusts was based on intelligible differentia and rational nexus to the legislative goal, hence satisfying Article 14 standards, relying on Shri Ram Krishna Dalmia v. Justice S.R. Tendolkar, [1959 SCR 279][1].

ii) They defended restrictions on trust property rights as reasonable under Article 19(5), given that the legislation aimed to ensure transparency, proper use, and protection of public religious assets.

iii) They argued that none of the provisions touched upon essential religious practices or altered internal doctrine; hence, the Act did not breach Articles 25 and 26.

iv) They clarified that the levy under Section 70 was a regulatory fee, not a tax, citing Mahant Sri Jagannath Ramanuj Das v. State of Orissa [1954 SCR 1046][2].

v) They contended that Section 55(2) only barred statutory appeals and did not limit constitutional remedies or Supreme Court jurisdiction under Article 133.

H) RELATED LEGAL PROVISIONS

i) Article 14 – Equality before law and equal protection of laws
ii) Article 19(1)(f) (now repealed) – Right to property
iii) Article 25 – Freedom of conscience and free profession, practice and propagation of religion
iv) Article 26 – Freedom to manage religious affairs
v) Article 27 – Freedom from taxation for promotion of religion
vi) Article 133 – Appellate jurisdiction of the Supreme Court in civil cases
vii) Bihar Hindu Religious Trusts Act, 1950 – Sections 2, 5–8, 28, 32, 55(2), 60, 70

I) JUDGEMENT

a. RATIO DECIDENDI

i) The Court held that the Act created permissible classifications under Article 14, due to essential religious, historical, and organizational distinctions between Sikhs, Jains, and Hindus.

ii) It ruled that Mahants held trust property not as owners but as trustees with a limited proprietary interest, which could be subject to reasonable restrictions under Article 19(5).

iii) The Court determined that administrative measures under Sections 28 and 60 aimed at trust accountability and did not interfere with religious doctrine or practice, hence complying with Articles 25 and 26.

iv) The levy under Section 70 was a regulatory fee for administrative services, not a religious tax, and therefore valid under Article 27.

v) Section 55(2) did not curtail constitutional appeals under Article 133; it only barred secondary appeals from High Court orders.

b. OBITER DICTA 

i) The Court noted that mere apprehension of abuse of administrative powers did not make the law invalid if the statutory design inherently included checks and balances.

c. GUIDELINES 

• Classification must meet the test of intelligible differentia and rational nexus to legislative objectives.

• Property rights of religious trustees are not absolute and can be reasonably regulated.

• Religious freedoms do not extend to mismanagement or secular aspects of endowments.

• Fees to regulate and audit trusts are valid if used for public purposes related to administration.

J) REFERENCES

a. Important Cases Referred

i) Shri Ram Krishna Dalmia v. Justice S.R. Tendolkar, [1959] SCR 279
ii) Mahant Sri Jagannath Ramanuj Das v. State of Orissa, [1954] SCR 1046
iii) The Commissioner, Hindu Religious Endowments, Madras v. Sri Lakshmindra Thirtha Swamiar of Shri Shirur Mutt, [1954] SCR 1005
iv) Ratillal Panachand Gandhi v. State of Bombay, [1954] SCR 1055
v) Sri Venkataramana Devaru v. State of Mysore, [1958] SCR 895
vi) Angurbala Mullick v. Debabrata Mullick, [1951] SCR 1125

b. Important Statutes Referred

i) Constitution of India, Articles 14, 19(1)(f), 19(5), 25, 26, 27, 133
ii) Bihar Hindu Religious Trusts Act, 1950
iii) Religious Endowments Act, 1863
iv) Charitable and Religious Trusts Act, 1920
v) Civil Procedure Code, 1908, Section 92