Supreme Court Upholds Mediation Agreement in Religious Property Dispute image for SC Judgment dated 06-01-2025 in the case of Shri Jain Shwetambar Shri Sang vs State of Rajasthan & Ors.
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Supreme Court Upholds Mediation Agreement in Religious Property Dispute

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The Supreme Court of India, in Shri Jain Shwetambar Shri Sangh Panjikrit Sanstha v. State of Rajasthan & Ors., delivered a landmark ruling settling a long-standing religious property dispute through mediation. The case involved two Jain religious groups contesting ownership and management rights over properties, including temples and a religious complex.

Background of the Case

The appellant, Shri Jain Shwetambar Shri Sangh Panjikrit Sanstha, challenged the Rajasthan High Court’s decision, which upheld a trial court’s ruling in favor of the respondent, Shri Jain Shwetambar Khartargachh Sangh. The dispute centered around ownership rights over the Dadabari complex and other religious properties in Ajmer.

Key Facts

  • The case involved a dispute over ownership of the Dadabari complex and two Jain temples in Ajmer.
  • The trial court ruled in favor of Shri Jain Shwetambar Khartargachh Sangh.
  • The appellant appealed to the Rajasthan High Court, which dismissed their case.
  • The Supreme Court, on December 1, 2023, referred the matter to mediation.
  • On December 7, 2024, a mediation agreement was signed between the parties, resolving the dispute.

Legal Issues

Appellant’s Arguments

The appellant contended that:

  • They had historical rights over the Dadabari complex and other disputed properties.
  • The lower courts failed to consider key historical and religious evidence.
  • The property management should be equally shared between the two sects.

Respondent’s Arguments

The respondent argued that:

  • The properties rightfully belonged to Shri Jain Shwetambar Khartargachh Sangh.
  • The appellant had no legal claim over the properties.
  • The trial court correctly ruled in their favor, and the High Court rightly upheld the decision.

Supreme Court’s Observations

1. Mediation as a Dispute Resolution Mechanism

The Court commended the parties for resolving the matter through mediation.

  • “Mediation is an effective tool for resolving long-standing disputes, particularly in religious and community matters.”
  • “The judiciary encourages mediation to avoid prolonged litigation and ensure amicable settlements.”

2. Terms of the Settlement

The settlement agreement included the following terms:

  • Shri Jain Shwetambar Khartargachh Sangh will have sole ownership and management of the Dadabari complex.
  • The appellant, Shri Jain Shwetambar Shri Sangh, will retain exclusive control over two Jain temples in Ajmer.
  • The respondent will pay ₹8.11 crore to the appellant as part of the settlement.
  • All pending litigation related to the dispute will be withdrawn and closed.

3. Judicial Precedents on Mediation

The Court referred to previous judgments endorsing mediation:

  • Afcons Infrastructure Ltd. v. Cherian Varkey Construction Co. (P) Ltd.: Recognized mediation as a preferred mode of dispute resolution.
  • Salem Advocate Bar Assn. v. Union of India: Emphasized the role of mediation in reducing judicial backlog.

Final Judgment

  • The Supreme Court disposed of the appeal and modified the lower courts’ judgments in accordance with the settlement.
  • The Court ordered that the terms of the settlement be incorporated into the final decree.
  • The concerned courts were directed to close pending cases related to the dispute.

Implications of the Judgment

This ruling has significant implications:

  • Encourages mediation in religious and community disputes.
  • Provides a structured approach for resolving property conflicts amicably.
  • Sets a precedent for judicial endorsement of out-of-court settlements.

The judgment strengthens the role of mediation in India’s legal system and upholds the principle of peaceful resolution in religious property disputes.


Petitioner Name: Shri Jain Shwetambar Shri Sangh Panjikrit Sanstha.
Respondent Name: State of Rajasthan & Ors..
Judgment By: Justice J.K. Maheshwari, Justice Rajesh Bindal.
Place Of Incident: Ajmer, Rajasthan.
Judgment Date: 06-01-2025.

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