Sri Venkataramana Devaruand Others v. The State of Mysore and Others (1957)
Sri Venkataramana Devaru and Others v. The State of Mysore and Others (1957)
1. Court:
Supreme Court of India
2. Background / Facts:
The case arose from a dispute over management and control of religious institutions, specifically temples in the State of Mysore (now Karnataka).
The petitioners were priests or devotees of a temple, challenging the interference of the State government in the administration of temple affairs under the Mysore Religious Endowments Act, 1951.
The petitioners contended that the management of the temple was under religious authorities or community and the state’s control violated their fundamental right to manage religious affairs.
The State argued that it had legislative competence and authority to regulate religious institutions for public welfare and better administration.
3. Legal Issues:
Whether the State Legislature of Mysore had the competence to enact laws regulating the management of religious institutions.
Whether the State’s intervention infringed on the right to manage religious affairs guaranteed under Article 26 of the Indian Constitution (Right to manage religious affairs).
The constitutional validity of the Mysore Religious Endowments Act, 1951.
Balance between State regulation and religious freedom.
4. Constitutional Provisions Involved:
Article 25: Freedom of conscience and free profession, practice, and propagation of religion.
Article 26: Freedom to manage religious affairs.
Entry 28 of List III (Concurrent List): Provides legislative competence over religion and religious endowments.
5. Judgment:
The Supreme Court held that Article 26 guarantees the right of every religious denomination to manage its own affairs in matters of religion, which includes managing places of worship.
However, this right is not absolute and is subject to the regulation made by the State for social welfare and public order.
The Court observed that the State has a valid legislative competence to regulate religious institutions, including their administration, finances, and properties, provided it does not destroy or discriminate against a particular religion or religious denomination.
The Mysore Religious Endowments Act was held constitutionally valid, as it aimed to ensure proper management and prevent mismanagement or corruption in religious institutions.
The ruling balanced the right of religious denominations to manage their affairs with the State’s power to regulate for the public good.
6. Legal Principles Established:
Right to manage religious affairs (Article 26): This right protects religious denominations but is not absolute and can be regulated by law for public welfare.
State’s legislative competence: The State can regulate religious institutions to prevent mismanagement and ensure public order.
Balance between religious freedom and public interest: The Court emphasized a balanced approach that respects religious rights while enabling State regulation.
No absolute immunity for religious institutions: Religious institutions cannot claim immunity from all State laws.
7. Related Case Law:
| Case | Principle |
|---|---|
| Bijoe Emmanuel v. State of Kerala (1986) | Right to religion under Article 25 includes freedom of conscience. |
| Church of God (Full Gospel) in India v. K.K.R. Majestic Colony Welfare Association (1996) | Right to manage religious affairs is subject to reasonable regulations. |
| The Commissioner, Hindu Religious Endowments, Madras v. Sri Lakshmindra Thirtha Swamiar of Sri Shirur Mutt (1954) | State control over religious endowments is constitutionally permissible. |
| S.R. Bommai v. Union of India (1994) | Emphasized secularism and the role of State in maintaining harmony. |
8. Significance:
The case is a landmark decision on the constitutional scope of religious freedom and the right to manage religious affairs in India.
It clarified that the State has a legitimate interest in regulating religious institutions to ensure proper administration and prevent exploitation.
The judgment helped shape subsequent laws regulating religious endowments and temples across India.
It also reinforced the principle that religious rights are not absolute and are subject to reasonable restrictions in the interest of public welfare.
9. Summary Table:
| Aspect | Details |
|---|---|
| Case Name | Sri Venkataramana Devaru and Others v. State of Mysore (1957) |
| Court | Supreme Court of India |
| Facts | Dispute over State’s regulation of temple management |
| Issue | Validity of State legislation under Article 26 and its limits |
| Held | Right to manage religious affairs is subject to State regulation for public welfare |
| Legal Principles | Balance between religious freedom and State control; State can regulate religious institutions |
| Significance | Landmark on religion and state regulation; State’s role in managing religious endowments recognized |
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