A) ABSTRACT / HEADNOTE

The case of Oachira Parabrahma Temple & Anr. v. G. Vijayanathakurup and Ors. deals with a long-standing dispute concerning the administration and management of the Oachira Parabrahma Temple in Kerala. The primary contention revolved around the conflicting authorities governing the temple’s affairs, particularly the role of the Administrative Head appointed by the High Court versus the elected Executive Committee. The temple, which operates several public welfare institutions, was entangled in legal challenges regarding its governance structure. The Supreme Court intervened to resolve the dispute by directing the appointment of a Retired High Court Judge as the new Administrative Head/Administrator to oversee fresh elections. The decision effectively nullified the previous appointments and directed a structured electoral process under strict supervision. The ruling emphasizes the necessity of protecting and preserving temples and their properties, ensuring that the administration remains effective and unbiased. The Court also modified the orders issued by the Kerala High Court and provided specific directions for conducting the elections, upholding the principle of fair and democratic governance of religious institutions.

Keywords: Oachira Parabrahma Temple, Temple Administration, Administrative Head, Election, Executive Committee, Advocate Commissioner, Kerala High Court, Supreme Court of India.

B) CASE DETAILS

• i) Judgement Cause Title: Oachira Parabrahma Temple & Anr. v. G. Vijayanathakurup and Ors.
• ii) Case Number: Civil Appeal No(s). 13708-13709 of 2024
• iii) Judgement Date: 03 December 2024
• iv) Court: Supreme Court of India
• v) Quorum: Sanjiv Khanna, CJI, Sanjay Kumar, R. Mahadevan, JJ.
• vi) Author: Justice R. Mahadevan
• vii) Citation: [2024] 12 S.C.R. 358; 2024 INSC 922
• viii) Legal Provisions Involved:
  • Indian Trusts Act, 1882
  • Hindu Religious and Charitable Endowments Act, 1951
  • Code of Civil Procedure, 1908
  • Constitution of India – Article 25, Article 26
• ix) Judgments Overruled (if any): None
• x) Case is Related to which Law Subjects:
  • Constitutional Law
  • Religious and Charitable Trusts
  • Civil Procedure
  • Administrative Law

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The case stemmed from an ongoing legal struggle over the administration and management of the Oachira Parabrahma Temple and its affiliated institutions. The temple, an ancient and unique religious institution, does not house a traditional idol or sanctum sanctorum but operates as a spiritual center overseeing a hospital, nursing college, and a school. Governance disputes arose when an Executive Committee elected in 2017 was later removed, and an Administrative Head was appointed by the High Court. The appellants, who were part of the elected committee, challenged the High Court’s decision to override the temple’s Bye-laws and place the administration under an unelected authority. The dispute further escalated when financial control was questioned, leading to contempt petitions. The Supreme Court was thus tasked with resolving governance ambiguity while ensuring the temple’s administration functioned lawfully and effectively.

D) FACTS OF THE CASE

1. The Oachira Parabrahma Temple in Kerala has historically been managed through a three-tier elected committee structure (General Board, Working Committee, and Executive Committee), as per its Bye-laws.
2. The Appellants, elected as Secretary and President of the Executive Committee in May 2017, claimed to have been removed illegally in April 2022 through a no-confidence motion.
3. A suit (OS.No.1/2006) was filed before the District Court, Kollam, to frame a Scheme for temple administration.
4. The High Court of Kerala, in RFA No. 562/2010, appointed an Advocate Commissioner to oversee the temple’s offerings, and later, a Retired High Court Judge as the Administrative Head for governance oversight.
5. In IA No. 5/2022, the High Court further removed the Executive Committee and installed an unelected body.
6. The Appellants contended that the High Court’s orders violated the Bye-laws and their right to govern until new elections.
7. The Supreme Court granted interim relief, allowing the elected committee to function temporarily.
8. The dispute intensified when financial transactions were blocked due to conflicting authority between the Administrative Head and the elected committee.
9. The matter was brought before the Supreme Court for final adjudication on governance structure and election supervision.

E) LEGAL ISSUES RAISED

1. Whether the High Court, after concluding RFA proceedings, had jurisdiction to entertain IA No. 5/2022 and pass further orders?
2. Whether the High Court was justified in appointing an unelected five-member committee to replace the elected Executive Committee?
3. Whether an Administrative Head could override the temple’s Bye-laws and existing electoral framework?
4. What is the extent of judicial intervention permissible in religious trust administration?

F) PETITIONER/APPELLANT’S ARGUMENTS

1. Violation of Bye-laws: The High Court’s order ignored the temple’s electoral process and violated its governance framework.
2. Jurisdictional Overreach: The High Court lacked authority to pass orders after disposing of the RFA.
3. Denial of Democratic Rights: The appointment of an unelected committee went against fundamental democratic principles.
4. Financial Control Dispute: Banks refused to recognize the elected committee due to unclear authority, hindering temple operations.

G) RESPONDENT’S ARGUMENTS

1. Need for Orderly Administration: The High Court’s intervention ensured a stable governance mechanism.
2. Legal Justification: Courts possess inherent jurisdiction in religious trust matters to protect public interests.
3. Election Delay: The Executive Committee’s term expired, necessitating judicial intervention.
4. Ensuring Transparency: The Advocate Commissioner and Administrative Head prevented mismanagement.

H) JUDGEMENT

a. RATIO DECIDENDI

1. Judicial Intervention in Temple Governance – The Court upheld judicial oversight in temple administration to prevent mismanagement.
2. Election Supervision is Mandatory – Governance must remain electoral, necessitating a fresh election under judicial supervision.
3. Administrative Head Cannot Override Elections – The Retired Judge’s role was confined to election supervision, not temple governance.

b. OBITER DICTA

1. Importance of Democratic Functioning – Religious trusts must comply with constitutional values ensuring fair and democratic governance.
2. Judicial Oversight is Limited – Courts should intervene only to facilitate fair elections, not usurp governance.

c. GUIDELINES ISSUED

1. New Administrative Head appointed (Retd. Justice K. Ramakrishnan) to oversee elections.
2. Elections to be conducted within four months.
3. Retired District Judge and Advocate to assist in the election process.
4. Existing administrative arrangements to continue until elections.
5. Trial Court directed to conclude final decree proceedings swiftly.

I) CONCLUSION & COMMENTS

The ruling reaffirms judicial oversight in religious trust administration while emphasizing the need for democratic governance. The Supreme Court’s directives ensure a structured, lawful, and fair electoral process, preventing arbitrary interventions. The case underscores the balance between religious autonomy and judicial oversight, reinforcing the principle of fair governance in religious institutions.

J) REFERENCES

Important Cases Referred:

• Sri Shirur Mutt Case, AIR 1954 SC 282
• Commissioner, Hindu Religious Endowments v. Sri Lakshmindra Thirtha Swamiar, AIR 1954 SC 282

Statutes Referred:

• Hindu Religious and Charitable Endowments Act, 1951
• Indian Trusts Act, 1882
• Constitution of India – Article 25, Article 26