The court affirmed that 'Guru Granth Sahib' is a juristic person, recognizing its authority to hold property and receive gifts, distinguishing it from idol worship.

1The question raised in this appeal is of far reaching consequences and is of great significance to one of the major religious followers of this country. The question is whether "the Guru Granth Sahib" could be treated as a juristic person or not ? If it is, then it can hold and use the gifted properties given to it by its followers out of their love in charity. This is by creation of an endowment like others for public good, for enhancing the religious fervour, including feeding the poor, etc. Sikhism grew because of the vibrating divinity of Guru Nanakji and the 10 succeeding Gurus, and the wealth of all their teachings is contained in 'Guru Granth Sahib'. The last of the living Guru was Guru Gobind Singhji who recorded the sanctity of "Guru Granth Sahib" and gave it the recognition of a living Guru. Thereafter, it remained not only a sacred book but is reckoned as a living Guru. The deep faith of every earnest follower, when his pure conscience meets the divine under current emanating from their Guru, produces a feeling of sacrifice and surrender and impels him to part with or gift out his wealth to any charity may be for Gurudwaras, dharamshalas, etc. Such parting spiritualises such follower for his spiritual upliftment, peace, tranquility and enlightens him with resultant love and universalism. Such donors in the past, raised number of Gurudwaras. They gave their wealth in trust for its management to the trustees to subserve their desire. They expected trustees to faithfully implement the objectives for which the wealth was entrusted. When selfishness invades any trustee, the core of trust starts leaking out. To stop such leakage, legislature and Courts step in. This is what was happening in the absence of any organised management of Gurudwaras, when trustees were either mismanaging or attempting to usurp such trusts. The Sikh Gurudwaras and Shrines Act, 1922 (VI of 1922), was enacted to meet the situation. It seems, even this failed to satisfy the aspirations of the Sikhs. The main reason being that it did not establish any permanent committee of management for Sikh Gurudwaras and did not provide for the speedy confirmation by judicial sanction of changes already introduced by the reforming party in the management of places of worship. This was replaced by the Sikh Gurudwaras Act, 1925 (Punjab Act No. 8 of 1925), under which the present case arises. This Act provided a legal procedure through which Gurudwaras and shrines regarded by Sikhs as essential places of Sikh worship to be effectively and permanently brought under Sikh control and management, so as to make it consistent with the religious followings of this community.

2 About 56 persons of villages Bilaspur, Ghodani, Dhamor, Lapran and Buani situated in the Village Bilaspur, District Patiala, moved petition under S.7(1) of the said Act for declaration that the disputed property is a Sikh Gurudwara. The State Government through Notification No. 1702 G. P., dated 14th September, 1962, published the aforesaid petition in the Gazette including the boundaries of the said Gurudwaras which were to be declared as Sikh Gurudwaras. Thereafter, a composite petition under S.8 and 10 of the said Act was filed by Som Dass, son of Bhagat Ram, Sant Ram son of Narain Dass and Anant Ram son of Sham Dass of Village Bilaspur, District Patiala, challenging the same. They claimed it to be a Dharamshala and Dera of Udasian being owned and managed by the petitioners and their predecessors since the time of their forefathers and that they being the holders of the same, received the said Dera in succession in accordance with their ancestral share. They also claimed to be in possession of the land attached to the said Dera. They denied it to be a Sikh Gurudwara. This petition was forwarded by the Government to the Sikh Gurudwara Tribunal, hereinafter referred to as "the Tribunal". In reply to the notice, the Shiromani Gurudwara Parbandhak Committee, hereinafter referred to as "the SGPC" (a