Supreme Court Rules on Temple Land Ownership: Madhya Pradesh Revenue Entries Declared Invalid

The case of State of Madhya Pradesh & Ors. v. Murti Shri Chaturbhujnath & Ors. dealt with the ownership and management of temple land and the correction of revenue records. The Supreme Court upheld the High Court’s ruling that changes made in the revenue entries were invalid, reinforcing the need to follow proper legal procedures for such corrections.

Background of the Case

The dispute arose when the State of Madhya Pradesh modified revenue records in 1979-80, recording the Collector as the ‘Manager’ of a temple’s land. The temple, located in Village Kharsod Kalan, District Ujjain, had been in the possession of its priests (Pujaris), who filed a suit to challenge the changes. The suit was initially dismissed but was later decreed in favor of the temple in the first appeal. The High Court upheld this ruling, leading the State to appeal to the Supreme Court.

Arguments by the Appellants (State of Madhya Pradesh)

The State contended that:

• The temple was public property, and placing the Collector as ‘Manager’ was necessary for its proper administration.
• The Pujaris were mere caretakers and had no ownership rights over the land.
• The land belonged to the Aukaf Department and was designated as “Devsthani Muafi” (land reserved for religious purposes).
• The priests had no “Bhumiswami Rights” over the temple land.

Arguments by the Respondents (Temple and Pujaris)

The temple and priests argued that:

• They never claimed ownership of the land but only sought to protect its existing status.
• The land had been gifted by Syed Mohammed Ali, the manager of the landlord Hakim, and had remained in peaceful possession of the temple.
• The unilateral correction of the revenue records was done without following the prescribed procedure under Section 115 of the Madhya Pradesh Land Revenue Code, 1959.
• The revenue records for 1969-70, 1970-71, and 1972-73 consistently listed the deity as the owner of the land.

Supreme Court’s Observations

The Supreme Court, led by Justices Navin Sinha and Sanjiv Khanna, ruled:

“The correction in the revenue records in 1979-80 was made in violation of the prescribed procedure under Section 115 of the Madhya Pradesh Land Revenue Code.”

The Court further observed:

“There is no material on record to suggest that the temple was being mismanaged, requiring it to be taken over by the Collector. The unilateral action of modifying revenue entries without a proper inquiry and notice to affected parties is unsustainable.”

Final Judgment

The Supreme Court dismissed the State’s appeal and ruled:

• The correction of revenue records was invalid as it was not done per Section 115 of the Madhya Pradesh Land Revenue Code.
• The temple’s ownership status, as recorded in earlier revenue documents, must be maintained.
• The Collector cannot claim managerial rights over the temple without following due process.

Conclusion

This judgment underscores the importance of following legal procedures when making changes to land ownership records. It affirms that unilateral actions by the government, without due process, cannot override longstanding property rights.

Petitioner Name: State of Madhya Pradesh & Ors..
Respondent Name: Murti Shri Chaturbhujnath & Ors..
Judgment By: Justice Navin Sinha, Justice Sanjiv Khanna.
Place Of Incident: Ujjain, Madhya Pradesh.
Judgment Date: 25-10-2019.

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