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2025 Supreme(Ker) 2640

IN THE HIGH COURT OF KERALA AT ERNAKULAM
N. NAGARESH, J.
Administrative Committee, South Kerala Diocese, Church Of South India, Lms Compound, Thiruvananthapuram, Represented By Its Administrative Secretary T. T. Praveen – Petitioner 
Versus
Director General Of Police, Kerala Police Headquarters, Vellayambalam, Thiruvananthapuram, Kerala and Ors. – Respondents
W.P.(C) Nos.25919 and 32108 of 2025
Decided On : 29-08-2025

Advocates Appeared:
For the Petitioner: Sri. T. Krishnanunni (SR.), Smt. Mariya Rajan, Sri. Shinu J. Pillai, Smt. S. Suja, Smt. Ann Mariya John, Sri. Felix Samson Varghese.
For the Respondents: Sri. S.V. Balakrishna Iyer (Sr.), Sri. R. Sunil Kumar, Sri. Reginald Valsalan, Sri. D. Justin, Smt. A. Salini Lal, Sri. Jinu P. Binu, Sri. S. Anil (Padinjarekota), Smt. Ann Maria Francis.

Disputes regarding the administration of private religious organizations fall under civil jurisdiction, and the High Court will provide police protection without adjudicating on internal authority issues.

Headnote:(A) Constitution of India - Article 226 - Writ petitions seeking police protection regarding administration and elections within a private religious organization - Both petitions involve disputes relating to authority and legality of Administrative Committees appointed for the administration. The Court found that such disputes are to be adjudicated by competent civil courts, not under Article 226. (Paras 20, 22, 25, 33)

(B) Legal standing - The Court emphasized the need for police protection in maintaining law and order without delving into the merits of the administrative disputes. (Para 20)

(C) Interim orders - Status quo regarding the administration period is maintained for appeal process while declining additional requests for police protection. (Para 25)

Facts of the case:
The Administrative Committee of the South Kerala Diocese sought police protection amid ongoing disputes over its authority and recent court judgments questioning its legitimacy. The opposing faction argued that the election process initiated by the Committee is unlawful per recent court findings.

Findings of Court:
The Court directed the interim status quo to remain in force for 90 days while acknowledging the pre-existing judicial orders for police protection for electoral processes.

Issues: The primary issue is determining jurisdiction regarding the administration of a private religious institution and the legality of its governing committees.

Ratio Decidendi: The Court ruled that disputes relating to the administration of private entities are beyond the scope of Article 226 while ensuring law and order through police protection if necessary.

Result: Writ petitions disposed of with specified directions for interim orders and police oversight.

Table of Content
1. police protection sought for church administration. (Para 1 , 2 , 3 , 4 , 5)
2. judicial appointments and church administration disputes. (Para 6 , 9 , 10 , 21)
3. arguments presented on election legality and administrative disputes. (Para 12 , 15 , 16 , 17)
4. writ jurisdiction limitations on church disputes. (Para 18 , 20)
5. apex court judgments impact church administration. (Para 26 , 31)
6. final orders regarding police protection and church administration. (Para 33)

JUDGMENT :

N. NAGARESH, J.

The petitioner in W.P.(C) No.25919/2025 is the Administrative Committee of South Kerala Diocese of the Church of South India (CSI). The writ petition has been filed seeking police protection for the smooth functioning of the Administrative Committee within LMS Compound, Palayam.

2. W.P.(C) No.32108/2025 has been filed by the 2nd respondent in W.P.(C) No.25919/2025, who is the first plaintiff in OS No.166/2021 of the II Additional Sub Court, Thiruvananthapuram. The 2nd respondent in W.P.(C) No.25919/2025 is a member of the South Kerala Diocese (SKD) of the CSI. The 2nd respondent also seeks police protection for the election to be held by respondents 6 to 8 as provided in Ext.P1 judgment. The parties and exhibits are referred to in this judgment as they are described/marked in W.P.(C) No.25919/2025.

Page 7

3. In W.P.(C) No.25919/2025, the petitioner states that in the year 2020, the Executive Committee of the CSI Synod appointed a new Committee for the SKD as per Ext.P1. Respondents 2 and 3, who were members of the expelled Committee, filed OS No.166/2021 seeking to declare that the Administrative Committee appointed as per Ext.P1 has no authority to continue. According to the petitioners, in the meantime, the Committee was reconstituted as per Ext.P3.

4. Various persons filed a number of Suits in the Hon'ble High Court of Madras against certain decision taken by the officers of the Synod of CSI. A Single Bench of the High Court of Madras declined their prayer for appointment of Interim Administrator for CSI. In appeal, a Division Bench of the Court appointed a Committee of Administrators to take over the administration of CSI, as per Ext.P4. Consequently, a Committee of Administrators consisting of Justice R. Balasubramanian (Rtd.) and Justice V. Bharathidasan (Retd.) took charge of the CSI.

Page 8

5. The said Administrators appointed Rev. Dr. Royce Manoj Victor as Bishop in Charge of the SKD. Mr. K.G. Simon was appointed as Administrative Secretary. The Bishop in Charge immediately cancelled the process of election for SKD. Aggrieved by Ext.P4 Division Bench judgment of the Madras High Court, Special Leave to Appeal Nos.9079-9081 of 2024 were filed in the Hon’ble Apex Court. The Apex Court initially passed Ext.P7 interim order directing that Administrators appointed by the High Court shall not take any decision regarding election to or administration of the CSI.

Page 9

6. After the said Ext.P7 interim order, the Sub Collector, Thiruvananthapuram held a reconciliation meeting between two factions of the SKD concerning the administration of the LMS Compound. Both parties agreed to maintain status quo as per Ext.P8. However, the Bishop appointed by the Committee of Administrators filed W.P.(C) No.21921/2024 to quash Ext.P8 settlement. The writ petition was dismissed as per Ext.P9 judgment. In appeal (W.A. No.917/2024), the Division Bench did not interfere

7. The office bearers of the SKD filed W.P.(C) No.19179/2024 and W.P.(C) No.19592/2024. This Court did not grant any order and left the petitioners to seek necessary clarification from the Apex Court as per Ext.P11 judgment. The Hon’ble Apex Court found in SLP(C) No.8229/2024 that there is no necessity to clarify its order, as per Ext.P12.

8. Later, the Hon’ble Apex Court delivered Ext.P13 judgment in SLP Nos.9079-9081 of 2024 upholding the election held to the posts of Deputy Moderator, General Secretary and Treasurer of the Synod of the CSI, subject to the outcome of the Suit pend

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