Gauhati High Court Rules Against State Interference in Religious Institution Management

Gauhati High Court Quashes Orders Interfering with Sri Sitaram Thakurbari Management

The Gauhati High Court recently delivered a significant judgment in Rajendra Das v. The State of Assam , (WP(C)/5616/2018 & WP(C)/5757/2018), asserting the right of religious denominations to manage their own affairs, a fundamental right enshrined in Article 26 of the Indian Constitution. Justice Kardak Ete's judgment, delivered on February 25, 2025, quashed government orders that took over the management of the Sri Sitaram Thakurbari , a temple in Guwahati.

Case Overview:

The case involved a dispute over the management and land ownership of Sri Sitaram Thakurbari . Rajendra Das , the anointed Mahant (head priest) of the temple, challenged orders issued by the Deputy Commissioner and District Magistrate of Kamrup (M) District, which appointed an additional deputy commissioner to take control of the Thakurbari. The government cited concerns about a breach of peace and a need to "streamline" the dispute. Other parties involved included the Thakurbari's managing committee and several individuals with claimed interests in the property.

Arguments Presented:

The petitioner argued that the government's actions violated Article 26 of the Constitution, which guarantees religious denominations the right to manage their own affairs. He contended that the land was private property and that the government's intervention was arbitrary and motivated by the vested interests of certain individuals seeking to seize the temple's property. He emphasized the long-standing traditions and customs of the ‘Ramanuj Panth’, which governed the appointment and authority of the Mahant.

The State government, on the other hand, contended that its actions were justified under Section 145 of the Code of Criminal Procedure (Cr.P.C.) to prevent a breach of peace. They cited reports of unrest within the temple premises as justification for intervention. Other respondents argued that the land belonged to the temple, not the Mahant personally, and therefore the administration had the right to intervene to protect the temple's interests.

Legal Precedents and Principles:

The court relied heavily on the Supreme Court's decision in Commissioner, Hindu Religious Endowments, Madras v. Sri Lakshmindra Thirtha Swamair of Sri Shirur Mutt (AIR 1954 SC 282) to emphasize the autonomy of religious denominations. The judge highlighted the principle that the state cannot interfere with the internal management of religious institutions unless there is a specific law allowing such intervention. Crucially, the court found no such law or regulation to justify the government's actions in this case, despite the government's claim to have acted under section 145 Cr.P.C.

Court's Decision and Implications:

The court held that the impugned orders were unsustainable and quashed them. While acknowledging the Deputy Commissioner's authority to maintain law and order, Justice Ete explicitly stated that this authority does not extend to interfering with the internal management of a religious institution absent specific legal authorization. The court's decision underscores the importance of upholding the fundamental right to religious freedom and autonomy as guaranteed under Article 26 of the Constitution. The judgment also serves as a strong reminder to state authorities to respect the independence of religious organizations. The court directed the parties to utilize other available legal remedies to resolve their disputes concerning the property and management of the Sri Sitaram Thakurbari .

Key Excerpts from the Judgment:

> "Under Article 26(b), therefore, a religious denomination .or organization enjoys complete autonomy in the matter of deciding as to what rites and ceremonies are essential according to the tenets of the religion they hold and no outside authority has any jurisdiction to interfere with their decision in such matters."

> "In the present case, however, no law or regulation appears to have been framed by the State as the State respondents could not place any such law or regulation."

> "Thus, I am of the view that for such dispute over the said property and the management of the Thakurbari, the parties have available remedy under the law."

The judgment in Rajendra Das v. The State of Assam provides crucial clarification on the boundaries of state power in relation to religious institutions in India. It serves as a precedent for future cases involving similar disputes and reinforces the constitutional protection afforded to religious denominations.