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2025 Supreme(Online)(Mad) 7315

IN THE HIGH COURT OF JUDICATURE AT MADRAS
Anita Sumanth, C. Kumarappan, JJ
B. Ramkumar Adityan – Appellant
Versus
District Collector – Respondent
WP(MD).No.26731 of 2025



Advocates:
For the Appellants/Petitioners: S. Sankar
For the Respondents: P. Thilakkumar, P. Kottaichamy, J. Ashok

State authorities are strictly obligated to implement and ensure compliance with judicial directives and circulars designed to prevent obscenity and maintain the spiritual, dignified ethos of public temple festivals.

Headnote:(A) Constitution of India - Article 226 - Public Interest Litigation - Temple festival rituals - Obscene and vulgar dance performances - Compliance with judicial directives - The court scrutinized reports and video evidence revealing non-compliance with its previous orders regarding cultural programs during religious festivals. It emphasized that authorities must implement earlier directives in letter and spirit. (Paras 1, 6, 7, 9, 10)

Facts of the case:
The petitioner filed this writ petition alleging that authorities failed to prevent inappropriate, vulgar, and obscene cultural events during the Dasara festival at a specific temple, contrary to previous high court orders and circulars issued by the Director General of Police meant to preserve the spiritual ethos of the festival.

Findings of Court:
The court found that the authorities were reluctant to implement its past orders. It expressed dissatisfaction with reports submitted by state officials that contradicted evidence of ongoing violations and reiterated that respondents remain bound by previous judicial directives.

Issues: Whether the temple authorities and local police have failed to implement judicial directives regarding the regulation of cultural events during the Dasara festival to uphold public decency and religious decorum.

Ratio Decidendi: Authorities are duty-bound to ensure that cultural events held during religious festivals do not degenerate into obscenity or vulgarity, and that they must strictly adhere to established police guidelines and prior court directions to maintain the sanctity and spiritual ethos of such events.

Result: Petition disposed of with liberty for the petitioner to take appropriate action for execution/redressal.

Table of Content
1. court oversight on festival management and conduct. (Para 1 , 2 , 3 , 4 , 5)
2. enforcement of dignity in religious festivals via previous judicial mandates. (Para 6 , 7 , 8 , 9 , 10 , 11)

ORDER

(Order of the Court was made by C.KUMARAPPAN, J.

1.The present writ petition has been filed as Public Interest Litigation for the relief of Writ of Mandamus or any other appropriate direction against the first, second and third respondents to take appropriate steps to implement the directives given by this Court in Writ petition in W.P (MD) No.12535 of 2023 dated 24.05.2023 and Circular Memorandum in Rc.003316/General I (1)/2023 dated 01.06.2023 of the Director General of Police, Tamil Nadu Police, during Dasara Festival at Arulmighu Mutharamman Thirukovil, Kulasekarapattinam, Thoothukudi District as mentioned in the representations of the petitioner dated 27.09.2023, 29.03.2025 and02.09.2025.

2.Heard Mr.S.Sankar, learned counsel appearing for the petitioner, Mr.P.Thilakkumar, learned Government Pleader appearing for the first respondent, Mr.P.Kottaichamy, learned Government Advocate appearing for the respondents 2, 3 & 5 and Mr.J.Ashok, learned Additional Government Pleader appearing for the respondents 4 & 6.

3. The learned counsel for the petitioner has raised his concern regarding the conduct of dance and music programs during the Navaratri Festival in Kulasekarapattinam. According to the petitioner, there is a likelihood of not following the earlier orders of this Court and that there is a possibility in conducting performance against the decorum and ethos of spiritual events. Hence, we deem it appropriate to direct the authorities to form a Committee and also directed the Committee to submit a report along with the video recording. For ready reference, this Court deems it appropriate to extract our order dated 24.09.2025 as under:-

“This writ petition is stated be be filed in public interest by a devotee of 'Arulmigu Mutharamman Thirukovil, Kulasekarapattinam, Thoothukudi District' ('Temple' / 'Temple in question').

2.His grievance concerns the conduct of dance and music festivals during the Navratri season, that are is not in alignment with decorum, particularly, when seen in the context of a temple festival. The Dussehra festival in the aforesaid temple has begun on 23.09.2025 and culminates with Vijaya Dashmi on03.10.2025.

3.The averments in the writ petition are supported by photographs, particularly those between pages 25 to 29, that reveal conduct of cultural events are inappropriate in a temple festival.

4.This is not the first instance when this Court has dealt with writ petitions with similar prayers, and the paper book contains several orders passed in identical situations in other temple festivals as well. (see orders dated 31.08.2017 (WP(MD)No.16077 of 2017) and 23.08.2018 (WP(MD)No.18348 of 2018); 14.09.2022 (WP(MD)No.21756 of 2022), 26.09.2022 (WP(MD)No.22591 of 2022), 24.05.2023 (WP(MD)No. 12535 of 2023) and 04.09.2023 (WP(MD)No.21507 of 2023), of these, WP(MD)No.16077 of 2017, WP(MD)No.18348 of 2018, WP(MD)No. 21756 of 2022, WP(MD)No.22591 of 2022, WP(MD)No.21507 of 2023 deal with the temple in question.

4.Mr.P.Thilakkumar, learned Government Pleader accepts notice for R1, Mr.P.Kottaichamy, learned Government Advocate accepts notice for R2, R3 & R5 and Mr.J.Ashok, learned Additional Government Pleader accepts notice for R4 & R6.

5. While the respondents would not dispute the position that the temple festival must comprise of programmes that align with the ethos of the temple, that are decent and dignified, they would point out that the photographs submitted do not relate to this year.

6. Mr.S.Sankar, appearing for the petitioner objects stating that even yesterday, similar dance and cultural events had taken place.

7. Hence and as a means of effective resolution that may be followed in later years as well, this Court directs the formation of a Monitoring Committee comprising (i) A nominee of the Tahsildar, Ku

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