The Supreme Court Justice Manoj Misra has recused himself from hearing a batch of review petitions filed by the International Society for Krishna Consciousness (ISKCON), Mumbai, challenging the Court’s verdict recognising ISKCON Bengaluru as an independent legal entity and the owner of the Hare Krishna Temple in Bengaluru.
The review proceedings arise from the Supreme Court’s May 2025 judgment in ISKCON Mumbai v. ISKCON Bangalore & Ors., which upheld the Bengaluru society’s independent legal status and its ownership of the temple property, rejecting ISKCON Mumbai’s claim that the Bengaluru organisation was its branch.
The dispute has a long procedural history involving rival claims over the legal identity, governance and control of the Bengaluru institution. ISKCON Mumbai has maintained that the Bengaluru organisation operates as its branch, while ISKCON Bengaluru asserts its status as a separate society registered under the Karnataka Societies Registration Act, 1960.
In its May 16, 2025 judgment, a Supreme Court Bench led by then Justice Abhay S Oka set aside the Karnataka High Court’s 2011 ruling that had favoured ISKCON Mumbai. The Court upheld the findings recognising ISKCON Bengaluru as a distinct legal entity and affirming its ownership of the Hare Krishna Temple complex.
ISKCON Mumbai subsequently sought a review of the judgment. In November 2025, the review proceedings resulted in a split verdict between Justices J K Maheshwari and A G Masih. While Justice Maheshwari allowed the applications seeking an open-court hearing of the review petitions, Justice Masih dismissed them, finding no apparent error warranting reconsideration.
Following the divergent opinions, the matter was placed before the Chief Justice of India for appropriate directions regarding its further hearing. The Supreme Court subsequently agreed to list the review petitions before a fresh Bench.
Justice Misra’s recusal means that the matter will have to be heard by a Bench constituted in accordance with the Supreme Court’s directions. The review proceedings will determine whether the Court’s earlier ruling recognising ISKCON Bengaluru’s independent status and ownership of the temple warrants reconsideration.
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