Supreme Court Dismisses Guru Manicka Prabhu Temple Head's Claim Over Chennai's Arulmighu Kamakala Kameshwarar Temple Property

The Supreme Court today dismissed an appeal filed by the spiritual head of Chennai's Guru Manicka Prabhu Temple, claiming a property adjacent to the Arulmighu Kamakala Kameshwarar Temple as his private property.

A bench of Justice Abhay Oka and Justice Augustine George Masih upheld the view of the division bench of the Madras High Court that the property was a trust property dedicated to the Arulmighu Kamakala Kameshwarar Temple.

"We have agreed with the division bench judgment. The appeal is dismissed", Justice Masih pronounced the verdict.

The Madras HC had dismissed an appeal filed against a judgment and decree passed by a Single Judge on April 26, 2011, regarding the property dispute.

The case revolves around the ownership and trust status of immovable property adjacent to the Arulmighu Kamakala Kameshwarar Temple (Plaintiff Temple), in Triplicane, Chennai. The appellant, claiming to be the spiritual head of Guru Manicka Prabhu Temple, claimed it as his private property, while the respondent, the Plaintiff Temple, claimed that the property was a trust property dedicated to the temple.

The suit was initially filed by the Plaintiff Temple seeking a declaration that the suit property vested absolutely in the Plaintiff Temple and demanding possession of the land.

The Plaintiff Temple was founded by Rai Raja Eswardoss Diawanth Bahadur, and after his death, his son T. Lakshmidoss and grandson T. Venkataprasad inherited the temple and associated properties. In 1914, Lakshmidoss and Venkataprasad were declared insolvent, and their estate, including the suit property, was vested in the Official Assignee (OA). The two later entered into a scheme of arrangement with their creditors to annul their insolvency, resulting in a decree in 1915, which included the division of their estate.

To settle debts, Lakshmidoss and Venkataprasad sold their estate to W. Ramakrishna Lala, who later established a trust. The trust deed, executed in 1917, outlined that all properties except the family house (the suit property) would be sold, and the proceeds used for maintaining Lakshmidoss, Venkataprasad, and their legal heirs.

In 1926, a suit was filed by one Devakinandan Dubey and sons seeking a declaration that the family house and adjacent properties were charged to repay debts owed by Lakshmidoss and Venkataprasad. They sought possession of the properties from the Official Assignee (OA) and the trustees and Mr. W. Ramakrishna Lala.

A compromise (razinama) was reached in the case, leading to a decree in 1929, which modified the 1917 trust deed. The compromise vested two houses with the spiritual head of the Manicka Prabhu Temple for maintenance of Lakshmidoss and Venkataprasad and, after their deaths, Venkataprasad's sister. After her death, the properties were to be used for maintaining the Manicka Prabhu and Kamakala Kameshwar Temples.

In 1954, the appellant, a spiritual head of the Manicka Prabhu Temple, filed applications and suits claiming hereditary trusteeship over the property, which were dismissed. Later, he caimed that it was actually his private temple, which was also dismissed. Ultimately, the courts concluded that the suit property was a trust property dedicated to the temples, rejecting claims of private ownership.

In 1999, after obtaining authorization from the Commissioner of HR & CE, the Plaintiff Temple filed the present suit on September 12, 1999, seeking possession of the suit property, claiming it as trust property. The Single Judge found the suit property was dedicated to the Plaintiff Temple. This was upheld by the division bench in the intra court appeal.

Thus, the appellant approached the Supreme Court in the present appeal.

The appellant contended that the suit property was not a trust property but a private property. He claimed that his predecessor had received the property through a registered conveyance deed dated August 28, 1931, and the spiritual head of the Guru Manicka Prabhu Temple was the absolute owner of the property, not a trustee.

The respondent contended that the suit property was a trust property and that the compromise decree of 1929 clearly indicated that the property and its income were to be used for the maintenance of both the Plaintiff Temple and the Manicka Prabhu Temple.

The HC examined the trust deed of 1917, the compromise decree of 1929, and the conveyance deeds of 1931. The HC noted that the provisions of the trust deed attached to the suit property, and the modifications introduced by the compromise decree vested the property in the spiritual head of the Manicka Prabhu Temple as a trustee, not as an absolute owner.

The HC further noted that the 1929 decree clearly stated that the income from the suit property was to be used for the maintenance of both temples. The property, therefore, remained under the trust, with the spiritual head of the Manicka Prabhu Temple serving only as a manager and trustee. The HC rejected the argument that the trust ceased to exist after the death of Lakshmidoss and Venkataprasad, as the decree expressly provided for the continuation of the trust and the use of the property's income for the upkeep of both temples.

The HC also dismissed the appellant's claim that the suit property had been in his possession for over 80 years and was therefore a private property. The HC held that possession of the property as a trustee did not confer ownership rights, and there was no evidence to suggest that the appellant or his predecessors had ever informed the Plaintiff Temple that the property was their private property.

Thus, the Madras HC dismissed the appeal.

Case no. – C.A. No. 8374/2024

Case Title – Siddaraja Manicka Prabhu Temple v. The Idol Of Arulmighu Kamakala Kameshwarar Temple