The court cannot resolve internal disputes of a private religious trust through Article 226 jurisdiction as they require complex factual determinations and are subject to alternative remedies.

ORDER :

NAGESH BHEEMAPAKA, J.

Petitioners state that the Church of South India Trust Association (CSITA) is a Religious Charitable Trust registered on 26.09.1947 under Section 26 of the Indian Companies Act, 1913, now governed by the provisions of the Companies Act, 2013. CSITA was registered with the Registrar of Companies under the Ministry of Company Affairs, Government of India, and continues to function under a valid license issued by the Government of Madras dated 25.09.1947. The Memorandum of Association and Articles of Association of CSITA, duly approved by the Registrar of Companies, remain in force, un-amended and unmodified, and constitute the supreme governing instruments regulating the administration, properties, finances and affairs of CSITA.

1.1. Petitioners contend that the CSITA is the sole and absolute owner of all properties transferred by missionary bodies, including the Methodist Missionary Trust Association (MMTA) which purchased and acquired extensive lands and properties across India and established churches, schools, colleges, hospitals, hostels, skill development centers and rehabilitation centers for educational, medical and charitable purposes. Upon the missionaries leaving India after Independence, all such properties were transferred in favour of CSITA in 1963; consequently, CSITA became the sole owner of the said properties spread across southern India, and their administration, management and finances vest exclusively in the Committee of Management constituted under the MoA and AoA of CSITA.

1.2. It is further stated, CSITA is geographically and administratively divided into 24 ecclesiastical districts known as dioceses for the purpose of administrative efficiency. The Medak Diocese is one such unit of CSITA, having jurisdiction over the districts of Hyderabad, Secunderabad, Medchal-Malkajgiri, Rangareddy, Sangareddy, Medak, Kamareddy, Siddipet, Nizamabad, Nirmal, Mancherial, Komaram Bheem Asifabad and Adilabad in the State of Telangana, with its administrative office situated at Secunderabad. According to Petitioners, each diocese functions through a Diocesan Council elected once in three years (Triennium), which is the final authority for internal administration of the diocese. The Bishop of the diocese is stated to be an employee of CSITA entrusted only with episcopal, ecclesiastical and ministerial functions. Administrative control is vested in the elected Diocesan Lay Secretary, Diocesan Treasurer and the Diocesan Executive Committee, who are responsible for governance, finance and administration of the diocese.

1.3. It is asserted, the Church of South India (CSI) is merely the ecclesiastical department of CSITA and is governed by an unregistered Constitution of CSI, which, according to Petitioners, has no statutory force and cannot override MoA and AoA of CSITA. The constitution of CSI was unilaterally drafted by a group of employees, namely bishops and clergymen, and that such employees are neither trustees nor owners of CSITA properties. Bishops, presbyters and pastors are employees appointed only to implement the policies and directions of the CSITA Committee of Management and have no independent authority to frame policy, administer trust properties or control electoral processes contrary to the governing documents.

1.4. Petitioners state that eligibility to be a member of the Church with voting rights and eligibility to participate in church administration is strictly governed by the Constitution of CSI and MoA and AoA of CSITA. It is asserted that every eligible member must be a baptised, adult communicant, professing, practising and witn