Religious Practices at Guruvayur: Tantri, Not Managing Committee, Holds Final Authority on Ritual Changes Under S.35 Guruvayur Devaswom Act: Kerala High Court

Kerala High Court: Tantri 's Decision Paramount in Guruvayur Temple's Religious Matters, Committee Cannot Alter Rituals Unilaterally

Ernakulam, Kerala – The Kerala High Court, in a significant ruling, has reaffirmed the supremacy of the Tantri (chief priest) in all religious, spiritual, ritual, or ceremonial matters pertaining to the Guruvayur Sree Krishna Temple. The Division Bench, comprising Justice Anil K. Narendran and Justice Muralee Krishna S. , set aside a resolution by the Guruvayoor Devaswom Managing Committee that altered the conduct of the ' Udayasthamana Pooja ', directing that any such change must be decided by the Tantri as mandated by Section 35 of the Guruvayur Devaswom Act, 1978.

Background of the Dispute

The writ petition [WP(C) NO. 11863 OF 2019] was filed by Sadasiva Subramanniam , a devotee whose family had an endowment for conducting the Udayasthamana Pooja . He challenged the Guruvayur Devaswom Managing Committee's decision (Resolution No.1 dated 26.10.2018) to conduct the Udayasthamana Pooja jointly in the name of five devotees on a single day, instead of exclusively for one devotee or family as per prior practice. The petitioner argued this change, communicated via a letter dated 17.11.2018, was against the Guruvayur Devaswom Act and that any modification to the pooja's performance required the approval and consent of the Temple Tantri .

Arguments Presented

Petitioner's Stance: The petitioner contended that the Devaswom 's decision to club offerings was arbitrary and infringed upon the established custom and his family's right stemming from their endowment (Ext.P1 communication dated 30.05.1978). He asserted that the Tantri 's consent was indispensable for any changes to temple rituals.

Guruvayoor Devaswom Managing Committee's Justification: The Managing Committee (Respondents 1 & 2) defended its resolution, stating it was based on the findings of an ' Ashtamangala Prasnam ' (an astrological consultation) held from 26.09.2018 to 02.10.2018, which purportedly suggested that Udayasthamana Pooja could be performed for five persons daily. They argued this would help clear a massive backlog, as bookings for the pooja were closed in 2007 with pending poojas extending beyond 2050. The Committee also claimed the then Tantri had concurred with the decision. While the cost per devotee was reduced from ₹1,50,000 to ₹1,00,000, the total estimated cost for the pooja with enhanced celebrations (including 3 caparisoned elephants) rose to ₹5,00,000. They also cited a past High Court observation in Rajan C.K. v. State of Kerala [AIR 1994 Ker. 179] suggesting consideration for plurality in performing the pooja.

The Tantri 's Position: The stance of the Tantri (Respondent 3) evolved through different affidavits. The then Tantri , Narayanan Namboothirippadu , in his counter affidavit (11.07.2019), stated he was bound by custom to conduct only one Udayasthamana Pooja per allotted day. He clarified that the Devaprashnam indicated such a group performance might be possible only with the consent of the Tantri , his family, and all parambaryakars (hereditary functionaries) . He confirmed he had not deviated from the old custom.

Later, an additional counter affidavit by the Devaswom (16.02.2023) claimed the new Tantri , BrahmasreeP.C. Dinessan Namboothirippad (who took charge after the former's demise on 25.10.2021), found the 5-person pooja unobjectionable. However, the current Tantri , P.C. Dinessan Namboothirippad , subsequently filed his own affidavit (23.05.2023), fully endorsing his predecessor's view. He reiterated that custom dictates one Udayasthamana Pooja , which is a complex ritual spanning three days, making it impossible to conduct multiple distinct poojas daily. He stressed that the Devaprashnam's suggestion was conditional upon comprehensive consent.

Court's Analysis and Reasoning: The Primacy of Section 35

The High Court meticulously examined the provisions of the Guruvayur Devaswom Act, 1978, and the Guruvayur Devaswom Rules, 1980. The judgment hinged on Section 35 of the Act , which unequivocally states:

> "(1) Nothing in this Act shall be deemed to authorise the Committee or the Commissioner or the Government to interfere with the religious or spiritual matters pertaining to the Devaswom . > (2) The decision of the Thantri of the temple on all religious, spiritual, ritual or ceremonial matters pertaining to the Devaswom shall be final, unless such decision violates any provision contained in any law for the time being in force."

The Court also noted Rule 6 of the Guruvayur Devaswom Rules, 1980 , which prohibits the Committee from altering or causing to alter the performance of customary rites and ceremonies in the temple.

The Court observed from the ' Prasnacharth ' (astrological findings report) that while the possibility of conducting the pooja for five devotees was indicated, it was explicitly stated that this "should be done after consultation with concerned persons and with proper legal arrangements" (translated from Malayalam).

Crucially, the Court found that: > "The pleadings and materials on record would not show that the then Tantri of Guruvayur Sree Krishna Temple... has taken a decision as per the requirements of sub-section (2) of Section 35 of the Act on the conduct of Udayasthamana Pooja by 5 devotees in a day."

The Court emphasized: > "In view of the prohibition contained in sub-section (1) of Section 35, nothing in the Act shall be deemed to authorise the 1st respondent Managing Committee or the Commissioner or the Government to interfere with the religious or spiritual matters pertaining to Guruvayur Devaswom . Therefore, a decision to permit the conduct of Udayasthamana Pooja by 5 devotees in a day has to be taken by the Tantri of the temple and not by the 1st respondent Managing Committee in which the Tantri is one among the members."

The Verdict

The Kerala High Court delivered the following orders:

1. Set Aside Committee's Decision: The resolution Ext.R1(a) taken by the Guruvayoor Devaswom Managing Committee to conduct Udayasthamana Pooja for 5 devotees in a day was set aside.

2. Tantri to Decide: The 3rd respondent Tantri was directed to take an appropriate decision on the matter, as per the requirements of sub-section (2) of Section 35 of the Guruvayur Devaswom Act, 1978, expeditiously, within a period of two months (as submitted by the Tantri 's counsel).

3. Maintain Status Quo: Until such a decision is taken by the Tantri , the existing practice in the conduct of Udayasthamana Pooja (as per the Tantri 's note Ext.R1(f)) shall be continued.

4. No Opinion on Cost: The Court clarified that it expressed no opinion on the fixation of the total expenditure for the Udayasthamana Pooja at ₹5,00,000.

Implications of the Judgment

This judgment strongly reinforces the statutory position of the Tantri as the ultimate authority in religious and ritualistic matters at the Guruvayur Temple. It underscores that administrative bodies like the Devaswom Managing Committee, while responsible for temple management, cannot unilaterally alter established religious customs or rites without a formal and explicit decision from the Tantri , as mandated by the Guruvayur Devaswom Act. The ruling serves as a crucial reminder of the distinct roles and the separation of powers in the administration of religious institutions governed by specific statutes.