Case Title: R.M. Sundaram @ Meenakshisundaram V. Sri Kayarohanasamy And Neelayadhakshi Amman Temple
According to the Supreme Court, a property's dedication as a religious endowment might be inferred from the circumstances rather than requiring an actual dedication or deed.
When ruling that Adipooram Thiruvabaranam, which consists of 26 pieces of jewellery, some of which are embedded with diamonds and precious stones, belongs to the deity Sri Neelayadhakshi Amman of the Sri Neelayadhakshi Amman Temple, the bench of Justices Ajay Rastogi and Sanjiv Khanna noted that it can be inferred that the property's private character has been extinguished from the circumstances and facts on record, including sufficient length of time, which shows user permitted for religious or public purposes.
This case resulted from a lawsuit brought by R.M. Sundaram, who claimed to be Muthuthandapani Chettiar's adoptive son and to have inherited the jewellery as his personal property. In order to "keep autonomous and exclusive possession and enjoyment of the Kudavarai" of the Temple, he had also requested a mandatory injunction from the court. The temple fought the action, claiming that the plaintiff lacked ownership of the suit jewellery and that Muthuthandapani Chettiar's care of the Kudavarai's keys was just an honorary duty. The jewellery was a special endowment tied to the temple, according to the temple, and was bestowed by Muthuthandapani Chettiar's forefathers to the idol/deity. The Trial Court rejected this lawsuit primarily on the grounds that Section 109 of the Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959 rendered it unmaintainable. This ruling was upheld by the first appellate court and then by the High Court. The Trial Court's declaration ruling in favour of the Temple in a lawsuit it brought forth was also upheld by the High Court.
The Apex Court bench remarked in the appeal that the three courts' conclusions of fact regarding the endowment of the suit jewellery are congruent. Referring to the rulings in the cases Deoki Nandan v. Murlidhar, The Commissioner for Hindu Religious and Charitable Endowments, Mysore v. Sri Ratnavarma Heggade (Deceased) by his L. Rs (1977) 1 SCC 525, M.R. Goda Rao Sahib v. State of Madras, Idol of Sri Renganathaswamy represented by its Executive Officer, Joint Commissioner v. P.K. Thoppulan Chettiar, Ramanuja Koodam Anandhana Trust, represented by its Managing Trustee and Others and M.J. Thulasiraman and Another v. Commissioner, Hindu Religious and Charitable Endowment Administration and Another, the court observed thus:
"In the context of the present case and the facts recorded above, it is clear that the suit jewellery was a 'specific endowment' for the performance of the specific service of adorning the deity, Sri Neelayadhakshi Amman, to be taken out in the Temple car and ratham in a grand procession during the Adipooram festival. Further, as explained below, it was a charity in favour of the Temple and was for a performance of a religious charity. The involvement of the family of the appellant was limited and restricted to retaining the keys of the Kudavarai and the iron safe which were to be opened at the time of the festival of Adipooram and the suit jewellery was to be taken out for the specific purpose of adorning the deity, Sri Neelayadhakshi Amman… Therefore, in view of the judgments quoted above and the aforesaid statutory provisions, it must be held that the case of the appellant that there was no endowment or specific endowment must fail and has no legs to stand on. The dedication of the suit jewellery does not require an express dedication or document and can be inferred from the circumstances, especially the uninterrupted and long possession of the suit jewellery by the respondent/Temple. The private character of the jewels had been extinguished long back and the appellant has no basis to claim that the suit jewellery was inherited by him from his adoptive parents. The endowment is clearly public in nature and for the purposes of performing religious ceremonies. As confirmed by three courts, with which we are in agreement, the suit jewellery was dedicated for a specific purpose and can only be used during the performance of the religious ceremony during the Adipooram festival."
The appellant's arguments about "Res Judicata" against the declaration suit filed by the Temple were likewise dismissed by the judge. In addition to dismissing the appeal, the court issued an order prohibiting the appellant from interfering in any way with the Temple authorities' authority to remove the suit jewellery from the Kudavarai whenever the situation calls for it. Alternatively, the Court directed that the appellant complies with any requests made by the Executive Officer and Trustees of the respondent/Temple to open the Kudavarai doors and remove the suit jewellery from the iron safe whenever necessary.