The court established that disputes regarding hereditary claims and functions related to temple duties should be resolved in civil court rather than through writ jurisdiction, emphasizing the secular nature of the Kazhakom role.

JUDGMENT :

Muralee Krishna, J.

The petitioners who are members of a Varrier family, namely, Thekke Varriam, filed these writ petitions under Article 226 of the Constitution of India, claiming hereditary Kazhakom rights in the Sree Koodalmanikyam Temple, Irinjalakkuda.

2. In both the writ petitions, the petitioners seek a writ of certiorari to quash Ext.P3 notification dated 11.10.2023, Ext.P4 revision notification dated 07.02.2023, Ext.P7 order dated 24.02.2025, passed by the 4^th respondent Administrator of Sree Koodalmanikyam Devaswom and Ext.P8 Koodalmankyam Devaswom Employees Regulations 2003 (‘the Regulations 2003’ in short) in so far as the recruitment to the post of Kazhakom in Sree Koodalmanikyam Temple. In W.P.(C)No.8588 of 2025, in addition to the above reliefs, the petitioner has also sought for a writ of mandamus commanding respondents 2 and 4 to consider Ext.P6 representation dated 10.02.2025 submitted by the petitioner to the 4^th respondent Administrator of Sree Koodalmanikyam Devaswom on 10.02.2025 in the light of Ext.P5 objection dated 16.07.2024 submitted by the 6^th respondent to the 2^nd respondent Koodalmanikyam Devaswom Managing Committee along with the opinion of respondents 7 to 12, after hearing the petitioner and respondents 6 to 14 and pass orders thereon, in accordance with law, within a time frame to be stipulated by this Court. Since the issues to be decided in these writ petitions are one and the same, they are being heard together and disposed of by this common judgment. The parties and documents are referred in this judgment as they are referred in W.P.(C)No.8588 of 2025, unless otherwise stated.

3. The pleadings in these writ petitions are almost the same. The petitioners state that they inherited the Kazhakom right in Sree Koodalmanikyam Temple, Irinjalakkuda, by birth. According to them, the Kazhakom rights of their family are the integral and inseparable part of the worship of Lord Bharata-Lord Sangameswara, and are religious, spiritual, ritualistic and ceremonial matters pertaining to Devaswom. The petitioners are devotees of Lord Bharata at Sree Koodalmanikyam Temple and persons having interest in the temple as defined in Section 2 (g) of the Koodalmanickam Devaswom Act , 2005 (‘The Act’ in short). Sree Koodalmanikyam Temple is the only ancient temple in India dedicated to the worship of Lord Bharata.

3.1. The secular administration, control and management of Sree Koodalmanikyam Temple vests in the 2^nd respondent Committee, which has been constituted under Section 3 of the Act. The 1^st respondent State constitutes the 2^nd respondent and appoints the 3^rd respondent for the purposes of the Act. The 1^st respondent exercises all pervasive control in the matters of appointment, administration, and functioning of the authorities under the Act, including respondents 2, 3 and 4. The State Government is exercising financial control over respondents 2 to 4 as well as the Devaswom. The 4^th respondent is a