Religious Institutions Governed by Endowments Act Are Amenable to Writ Jurisdiction: Telangana High Court - 2026-06-08

Temple Governance Under Scrutiny: High Court Clarifies Writ Jurisdiction Over Religious Bodies

In a significant ruling concerning the administration of religious institutions, the High Court for the State of Telangana has affirmed that temple management committees, even when registered as private societies, are amenable to the courts' writ jurisdiction when they perform functions governed by the state’s Endowments Act.

The case, Nagilla Srinivas v. The State of Telangana and Others , centered on the management of the historic Sri Kanyaka Parameshwari Devasthanam in Secunderabad, an institution of immense cultural importance to the Arya Vysya community.

The Conflict: Tradition vs. Transformation

The dispute arose from a series of allegations regarding the unauthorized demolition and reconstruction of the temple. The petitioner, Nagilla Srinivas, contended that two competing committees—both claiming registration under the same number—had engaged in unilateral decisions, including the relocation of the presiding deity to the first floor without adherence to Vaastu Shastra or consultation with a qualified Sthapathi .

Further, the petitioner alleged the collection of approximately Rs. 16 crores from devotees, handled without transparent auditing or oversight, a direct violation of the Telangana Charitable and Hindu Religious Institutions and Endowments Act, 1987 .

Arguments on Maintainability

The respondents argued that because they were registered as societies under the Telangana Societies Registrations Act, they were effectively private entities and thus not amenable to the writ jurisdiction of the High Court under Article 226.

However, Justice Laxmi Narayana Alishetty dismissed this narrow view. The Court held that despite their corporate registration, the institutions exist for religious purposes and are governed by state law. Their failure to comply with statutory obligations—such as the submission of annual budgets and proper financial reporting—constituted a breach of public duty.

Legal Analysis and Precedents

The Court relied on a robust line of jurisprudence, including the landmark judgment in Andi Mukta Sadguru Shree Muktajee Vandas Swami Suvarna Jayanti Mahotsava Smarak Trust v. V.R. Rudani , where the Supreme Court observed that the power of mandamus should be available to ensure justice is not denied by technical compartmentalization.

Justice Alishetty emphasized that:

> "Some of the duties to be performed by [the committees] assume the character or nature of statutory duties or public functions which are closely related to functions performed by State in its sovereign capacity, therefore, respondent Nos.9 to 11 are amenable to writ jurisdiction."

Court’s Decision: A Path for Redressal

While acknowledging the gravity of the allegations regarding the sanctity of the temple and the handling of funds, the Court determined that the technical details of construction and religious rituals required a specialized investigation rather than judicial findings of fact.

The Court has remanded the matter to the competent authority under the Endowments Act. The respondent committees are now tasked with submitting all accounts, expert advice from Sthapathis , and documentation regarding the consecration rituals.

Key Observations

The Court underscored the breadth of Article 226 in preventing institutional mismanagement:

• "Mandamus is a very wide remedy which must be easily available 'to reach injustice wherever it is found'."
• "The idol cannot be removed permanently to another place, because that would be tantamount to establishing a new temple."
• "Even if it be assumed that no prayer for grant of a writ of mandamus was made, even orally or in pleadings, it was open for the High Court to mould and grant the relief."

Impact on Future Cases

This order serves as a stern reminder to private bodies managing public religious institutions that their status as a "society" does not grant them immunity from oversight. By prioritizing the regulation of religious institutions over the "technicalities" of their corporate registration, the Telangana High Court has ensured that the management of community trusts remains accountable to the devotees and the statutes meant to protect them.