The court held that for an interim injunction restraining an election process, the petitioner must clearly establish a prima facie case, balance of convenience, and potential irreparable injury; courts will not interfere with an ongoing election process when the process appears to adhere to constitutional rules, especially if the suit is filed with undue delay.

JUDGMENT

This Civil Miscellaneous Appeal has been preferred against the fair and Decretal Order made in I.A.No.2 of 2025 in O.S.No.1342 of 2025 on the file of the I Additional District Judge, Coimbatore dated 18.11.2025 by the plaintiff herein.

2. Parties are indicated herein as per their litigative status and ranking before the trial Court.

3. Details of the affidavit is stated in brief:

Petitioner is the plaintiff in the suit. Suit is laid for the relief as given hereunder:

(i) To declare the appointment of Lay sub Committee issued by the 3rd defendant for conducting the Bishopric elections to the 3rd defendant herein dated 05.09.2025 as illegal and it is null and void and it cannot be legally valid and binding upon the plaintiff.

(ii) By passing Order of permanent injunction restraining the defendants 3 and 4 from conducting any elections to the panel of Bishopric of CSI, Coimbatore Diocese on 22.11.2025.

3.1. The Church of South India [hereinafter mentioned as CSI] is an autonomous Church constituted by the Union of Churches of South India in the year 1947. The Administration and the governance of the CSI is governed by the constitution of CSI. Each Diocese has its own constitution and the said constitution shall be in conformity with the constitution of CSI, (i.e.,) 2nd defendant. Petitioner is a Presbyter in the 3rd defendant Diocese.

3.2. Election is held for each and every position within the Diocese and election process is held for the purpose of selecting candidates to become members of the Diocese Council, the Executive Committee, Bishops, etc. Violation of the constitutional process of the CSI Synod, and principles of natural justice undermines the sanctity of electoral procedures. On 05.09.2025, the 3rd defendant issued a letter to all the Presbyters of the Coimbatore Diocese. As per the said letter, it is learnt that the 1st defendant has forwarded a letter on 21.08.2025 with regard to mandate issued by the 1st defendant for the purpose of conducting Bishopric elections. For the election of the Bishop, democratic process of election has to be followed. As per the said letter, Executive Committee meeting was allegedly held on 26.08.2025 and members were appointed to the Sub Lay Committee (4th defendant) as per CSI Constitution. Copy of the mandate of the 1st defendant dated 21.08.2025 was not issued to the members of the diocese.

3.3. As per Clause 2 of Chapter VI, the 1st defendant must send a mandate to the Secretary to summon a meeting of the Diocesan Council to arrange for election of panel of names of the Bishopric atleast six months prior to the retirement of the sitting Bishop. Chapter VI Rule 5 says that “the moderate shall send his mandate only after ascertaining existing Diocesan Council has atleast six months from the date of receipt of the mandate before its term expires. In case the existing council has only less than six months before the expiry of its term, he shall send his mandate only after the succeeding Diocesan Council has been constituted and such succeeding Diocesan Council can elect the panel.”

3.4. As per Clause 5 of Chapter VI it stipulates that the Secretary must summon a meeting of the Executive Committee of the Diocesan Council who is donned with the responsibility of selecting committee of members. 4th respondent shall act as a Chairperson of the special meeting of the Diocesan Council which shall be convened for the purpose of conducting the election of the Bishop.

3.5. The 1st defendant has failed while carrying