Dispute Over Gurudwara Board Nominations: Supreme Court’s Landmark Ruling

The Supreme Court of India, in its judgment on August 20, 2020, addressed a significant legal dispute regarding the nomination of members to the board of the Nanded Sikh Gurudwara Sachkhand Shri Hazur Apchalnagar Sahib. The case, involving Sardar Bahginder Singh as the appellant and Sardar Manjieeth Singh Jagan Singh & Others as the respondents, revolved around conflicting claims over the nomination process.

The judgment provided a critical interpretation of the Nanded Sikh Gurudwara Sachkhand Shri Hazur Apchalnagar Sahib Act, 1956 and upheld the importance of procedural adherence in religious institution management.

Background of the Case

The dispute centered on the nomination of four members to the Gurudwara Board under Section 6(1)(viii) of the Nanded Act, 1956. The law stipulates that four members are to be nominated by the Sachkhand Hazuri Khalsa Diwan, Nanded. However, multiple conflicting nominations emerged, leading to a legal battle.

The Maharashtra government intervened and issued a notification appointing four board members. This notification was challenged in the Bombay High Court, which ruled that the state government had overstepped its authority. The ruling was then appealed in the Supreme Court.

Petitioners’ Arguments (Sardar Bahginder Singh & Others)

The petitioners contended that:

• The Maharashtra government had the right to intervene in the nomination process due to ongoing disputes within the Diwan.
• Past practices allowed the government to finalize nominations when factions within the Diwan failed to reach a consensus.
• The High Court erred in ruling that only the Diwan could nominate members without government oversight.

Respondents’ Arguments (Sardar Manjieeth Singh Jagan Singh & Others)

The respondents countered that:

• The nomination power is explicitly vested in the Sachkhand Hazuri Khalsa Diwan under the Act.
• The state government had no authority to override the Diwan’s decisions or assume nomination powers.
• The High Court was correct in ruling that the government’s notification was invalid.

Supreme Court’s Observations

The Supreme Court meticulously analyzed the legal framework governing the Gurudwara Board’s composition. Key observations included:

• The Nanded Act, 1956, clearly entrusts the power of nomination under Section 6(1)(viii) to the Sachkhand Hazuri Khalsa Diwan.
• The Maharashtra government’s role was limited to overseeing procedural compliance, not making direct nominations.
• Allowing government intervention in religious board appointments would set a dangerous precedent, undermining religious autonomy.

Important Verbatim Observations by the Supreme Court

The Court, in its judgment, stated:

“The authority to nominate four members under Section 6(1)(viii) is exclusively vested in the Diwan. The state government cannot usurp this power or act beyond its legal mandate.”

“In a system governed by the rule of law, discretion and exercise of power must be confined within defined limits. The decision of the government to issue the notification is arbitrary and cannot withstand judicial scrutiny.”

Final Verdict

The Supreme Court ruled that:

• The Maharashtra government’s notification appointing board members was invalid and quashed.
• The power of nomination belongs solely to the Sachkhand Hazuri Khalsa Diwan.
• The Diwan must finalize nominations within three months under the supervision of the Assistant Charity Commissioner.
• The Assistant Charity Commissioner is responsible for determining the eligible voting members of the Diwan.

Impact of the Judgment

This landmark ruling has significant implications for religious institution governance:

• It reinforces the autonomy of religious boards in managing their affairs without government interference.
• It upholds the rule of law by ensuring that nominations follow legally prescribed procedures.
• It prevents the misuse of state power in religious matters.
• It establishes a legal precedent for similar cases involving the governance of religious institutions.

The Supreme Court’s ruling ensures that religious institutions retain their autonomy while following due process, setting a crucial legal standard for future governance disputes.

Petitioner Name: Sardar Bahginder Singh.
Respondent Name: Sardar Manjieeth Singh Jagan Singh & Others.
Judgment By: Justice Dhananjaya Y. Chandrachud, Justice K.M. Joseph.
Place Of Incident: Nanded, Maharashtra.
Judgment Date: 20-08-2020.

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Download Judgment: Sardar Bahginder Sin vs Sardar Manjieeth Sin Supreme Court of India Judgment Dated 20-08-2020.pdf

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