State is Custodian, Not Owner of Temple Land: Supreme Court

A Supreme Court bench comprising Justice PS Narasimha and Justice Alok Aradhe has delivered a landmark judgment protecting religious endowments in K. Ramalingam and Others v. Government of Tamil Nadu.

The Core Constitutional Principle: The Supreme Court firmly established that the State acts merely as a custodian and regulator of temple properties under the Hindu Religious and Charitable Endowments (HR&CE) Act, not as their owner. The Bench emphasized that property dedicated to a deity is held in trust for the deity and its worshippers, and cannot be given away gratuitously—even for a laudable public purpose.

Key Findings of the Judgment:

• Gift Deed Voided: A gift deed executed by a temporary trustee, which transferred 1 acre and 10 cents of land belonging to the Nagapalayam Mariamman-Ponnachiamman Temple to the Tamil Nadu Government for a Taluk Office, was declared null and void.

• Statutory Violation: The Court ruled that the transaction violated Section 41(1) of the Tamil Nadu HR&CE Act, 1959, which strictly prohibits the gifting of inam land granted for the support or maintenance of a religious institution.

• No Unfettered Disposition: The administration of charitable trust property carries a duty of preservation. Temple land cannot be casually disposed of by whoever holds the office of trustee.

• Retrospective Rent & Costs: Since public funds had already been used to construct the Taluk Office, the Court did not annul the lease, but ordered the State to pay a revised fair rent of ₹31,000 per month retrospectively from March 8, 2019. The State was also slapped with costs of ₹1,00,000 for persistently defending an illegal transfer that its own departments knew lacked legal sanction.

The Supreme Court directed that every decision regarding temple properties must be guided solely by the best interests of the trust, never by the administrative convenience of the Government.

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