The Supreme Court has clarified that mere managerial or supervisory control over a religious institution did not establish legal ownership or title to the property by itself.
Setting aside a Rajasthan High Court verdict, which upheld the claim of a respondent society over the Moorti Swarup Shri Govardhan Nath Ji temple in Kota, the Bench of Justice Vikram Nath and Justice Sandeep Mehta held that participation in administrative functions, including the appointment of priests, could not be treated as conclusive proof of proprietary rights in a title dispute.
The High Court had affirmed the trial court’s decree primarily on the basis that the respondent exercised supervisory and managerial control over the temple’s affairs. The Apex Court found this reasoning legally unsustainable and contrary to settled principles governing adjudication of title suits.
It reiterated that in civil disputes relating to immovable property, the burden of proof lies on the plaintiff to establish a clear and legally cognisable title through documentary evidence such as a deed of dedication, endowment, or any other valid instrument demonstrating vesting of property rights.
The Court observed that the lower courts had misdirected themselves by focusing on the alleged weaknesses in the defendant’s claim instead of examining whether the plaintiff had independently discharged the burden of proving title. It held that the failure of the defendant to establish ownership could not strengthen the case of the plaintiff in law in the absence of affirmative proof.
The Bench noted that the respondent society had failed to produce any legally admissible evidence demonstrating ownership or vesting of the temple property. There was no material on record, such as a deed of endowment or any documentary proof, to substantiate its claim. In such circumstances, reliance solely on administrative control or participation in temple management was insufficient to confer proprietary rights, it added.
Accepting the appeal filed by the appellant, who claimed succession-based rights as caretaker, the top court of the country set aside the High Court verdict and held that the decree in favour of the respondent could not be sustained in law due to the lack of proof of title.
The post Supreme Court rejects supervisory role as proof of ownership in Kota temple dispute appeared first on India Legal.