Supreme Court: Temple Management Or Appointment Of Pujaris Does Not Confer Ownership Rights Over Property

News Citation : 2026 LN (SC) 448

May 6, 2026 : The Supreme Court has held that the mere exercise of supervisory or managerial control over a temple, or participation in the appointment of “pujaris”, does not by itself establish ownership rights over temple property. Setting aside concurrent findings of the Rajasthan High Court and Trial Court, the Apex Court dismissed a suit filed by the Gurjar Goud Brahmin Rampura Society, Kota, seeking possession and control of the temple property.

A Division Bench comprising Justice Vikram Nath and Justice Sandeep Mehta observed that the plaintiffs had failed to establish title over the disputed property through legally admissible evidence.

The Court stated:

“The mere fact that the society exercised certain supervisory or managerial functions over the temple or participated in the appointment of ‘pujaris’ would not ipso facto confer title upon it.”

Background

The dispute concerned the ancient temple “Moorti Swarup Shri Govardhan Nath Ji” situated at Rampura Bazar, Kota. The respondent-plaintiffs, comprising a registered society and its members, claimed that the temple and its associated properties belonged to the Gurjar Goud Brahmin Rampura Society, Kota. According to the plaintiffs, the society administered the temple and appointed caretakers or pujaris to manage its affairs.

The plaintiffs contended that in 1951, the appellant-defendant Kishan Chand was appointed as caretaker of the temple and was paid remuneration from income generated by temple shops. Later, in 1976, when the appellant asserted ownership over the temple property, the society issued a legal notice and subsequently filed a civil suit seeking his removal as pujari and restoration of possession.

The Trial Court decreed the suit in favour of the society, and the Rajasthan High Court affirmed the decree in appeal.

Supreme Court’s Findings

Allowing the appeal, the Supreme Court reiterated the settled principle that in a suit for declaration of title, the burden squarely lies on the plaintiff to prove ownership through cogent evidence.

The Bench observed that the courts below had fundamentally erred by focusing on the alleged weakness of the defendant’s claim instead of examining whether the plaintiffs had independently established title.

The Court held that the documents relied upon by the plaintiffs merely reflected arrangements regarding temple management and appointment of pujaris, but did not constitute title documents.

The judgment noted:

“There is no deed of dedication, no document of endowment, nor any legally admissible evidence to show that the property stood vested in the respondent-society.”

The Bench further clarified that management of a religious institution and ownership of its properties are distinct legal concepts and cannot be conflated. Even assuming the defendant failed to conclusively prove hereditary succession or title, such failure would not automatically benefit the plaintiffs unless they independently proved ownership.

Accordingly, the Supreme Court set aside the Rajasthan High Court judgment dated September 28, 2007, and dismissed the suit filed by the respondent-society.

Appearance

Senior Advocate Sushil Kumar Jain appeared for the appellant along with Advocates Christi Jain, Akriti Sharma, Om Sudhir Vidyarthi, Aditya Jain, Siddharth Jain, Yogit Kamat, and AOR Pratibha Jain.

AOR Ajay Choudhary appeared for the respondents.

Case Details

Case Title: Kishan Chand (Dead) Through LRs v. Gautam Gaur Hitkarak Sabha, Kota & Ors.