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Citation: 2025 (4) KLR (SC) 10 : 2025 INSC 465
Court: Supreme Court of India, Civil Original Jurisdiction
Bench: Justice B.V. Nagarathna, Justice Satish Chandra Sharma
Case Number: Writ Petition (C) No. 476/2012, with Writ Petitions (C) Nos. 1432/2019, 1147/2021, 148/2024
Date of Judgment: April 1, 2025
Constitutional Law – Article 32 – Jurisdiction – Challenge to provisions of Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959, Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, 1987, Pondicherry Hindu Religious Institutions Act, 1972, and Telangana Hindu Religious and Charitable Endowments Act, 1987.
Petitioners sought declaration of provisions as ultra vires Articles 14, 19, 25, 26, 29, and 31A – Supreme Court declined to adjudicate – Held, challenges to state-specific legislation more effectively addressed by respective High Courts due to distinct legislative schemes and socio-cultural contexts – Liberty granted to petitioners to approach jurisdictional High Courts – High Courts advised to consider historical, socio-economic, and religious aspects and may constitute Expert Committees.
Writ petitions disposed of.
Facts
The petitioners filed multiple writ petitions under Article 32 of the Constitution of India, challenging the constitutional validity of various provisions of:
- Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959 (specific sections listed in each petition).
- Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, 1987.
- Pondicherry Hindu Religious Institutions Act, 1972.
- Telangana Hindu Religious and Charitable Endowments Act, 1987 (in Writ Petition No. 148/2024).
The petitioners sought declarations that these provisions were ultra vires Articles 14, 19(1)(g), 25, 26, 29, and 31A of the Constitution, alleging violations of equality, freedom of profession, freedom of religion, and rights to manage religious institutions. Additional reliefs included quashing specific rules, orders, and appointments under these Acts, as well as mandamus for investigations and audits of temple administration.
Issues
- Are the challenged provisions of the Tamil Nadu, Andhra Pradesh, Pondicherry, and Telangana Hindu Religious and Charitable Endowments Acts unconstitutional and ultra vires Articles 14, 19, 25, 26, 29, and 31A of the Constitution?
- Should the Supreme Court directly adjudicate these challenges, or should the petitioners approach the respective High Courts?
Arguments
- Petitioners: Argued that the impugned provisions infringe constitutional rights by imposing excessive state control over Hindu religious institutions, restricting freedom of religion, and violating equality and property rights. They sought interim restraints on the enforcement of these provisions and additional reliefs like investigations into temple mismanagement.
- Respondents: Represented by senior counsel for Tamil Nadu, Andhra Pradesh, Telangana, and the Union of India, they defended the constitutional validity of the Acts, emphasizing the distinct legislative schemes and socio-cultural contexts of each state.
Judgment
The Supreme Court disposed of the writ petitions without adjudicating the constitutional validity of the challenged provisions. Key points of the judgment:
- Jurisdictional Observation: The Court noted that the challenged provisions belong to distinct state legislations (Tamil Nadu, Andhra Pradesh, Pondicherry, and Telangana). The schemes of these Acts vary, and the respective High Courts are better positioned to evaluate the provisions in their socio-economic, cultural, and religious contexts.
- Liberty to Approach High Courts: The Court reserved liberty for the petitioners to file fresh writ petitions before the jurisdictional High Courts to challenge the provisions of the respective Acts.
- Guidance to High Courts: The Court suggested that High Courts may consider the historical, socio-economic, cultural, and religious dimensions of the matter, including prior judicial verdicts. They may also constitute Expert Committees to assist in decision-making, if deemed necessary.
- Disposal of Applications: All pending applications, including those for intervention/impleadment, were disposed of.
Ratio Decidendi
The Supreme Court refrained from exercising its jurisdiction under Article 32, holding that challenges to state-specific legislation are more effectively addressed by the respective High Courts, which can better appreciate the local context and nuances of the legislative schemes.
Obiter Dicta
The Court emphasized the importance of considering the historical and socio-cultural aspects of religious endowments when adjudicating such challenges. It also highlighted the potential utility of Expert Committees in assisting High Courts.
Significance
This order underscores the Supreme Court’s preference for decentralizing constitutional challenges to state legislation, particularly when they involve complex local contexts. It reinforces the role of High Courts as primary forums for such disputes and encourages a nuanced approach to issues involving religious institutions.