Supreme Court Refrains from Intervening in Andhra Pradesh Mutt Eviction
- ByAdmin --
- 27 Jun 2025 --
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The Supreme Court of India has declined to interfere with the Andhra Pradesh High Court’s judgment barring state intervention in the administration of the Ahobilam Mutt and its affiliated temple, Sri Lakshmi Narasimha Swamy Devasthanam. The decision reinforces key constitutional protections for religious freedom, denominational autonomy, and limits on executive overreach under Article 26(d) of the Constitution.
Background of the Case
The dispute arose when the Andhra Pradesh government, acting under the Charitable and Hindu Religious Institutions and Endowments Act, 1987, appointed an Executive Officer (EO) to oversee the temple’s functioning.
The High Court quashed the appointment, holding that:
- The temple is an integral part of the Ahobilam Mutt and falls under its hereditary management.
- Article 26(d) guarantees religious denominations the right to manage their own religious affairs without state interference.
- The state failed to show any instance of mismanagement that would justify its action.
On appeal, the Supreme Court refused to disturb the High Court’s factual findings or re-examine the constitutional analysis, thereby upholding the Mutt’s right to manage the temple.
Legal Principles Reaffirmed
1. Article 26(d) – Denominational Autonomy
The Court reiterated that every religious denomination or section thereof has the right to manage its own affairs in matters of religion. This includes the administration of temples that are historically and functionally tied to the denomination.
2. Limits on State Power under Endowments Law
The Court held that statutory provisions under the Endowments Act cannot override fundamental rights unless there is clear and substantiated evidence of mismanagement or illegality.
3. Recognition of Functional Unity Across States
Although the Ahobilam Mutt is based in Tamil Nadu and the temple is located in Andhra Pradesh, the Court recognized their functional and historical unity. The longstanding, undisputed administration by the hereditary Mathadipathi strengthened the case against state interference.
Observations by the Supreme Court
The Court questioned the necessity of executive control, remarking in substance that religious institutions should be managed by religious authorities unless there is compelling reason to intervene.
It also emphasized the limited scope of its appellate jurisdiction under Article 136, noting that it is not bound to re-adjudicate settled findings of fact by High Courts.
The statutory authority granted by the Endowments Act was found insufficient to displace the constitutional right to religious self-governance.
Relevant Constitutional and Statutory Provisions
- Article 26(d) of the Constitution: Grants religious denominations the right to manage their own affairs.
- Article 136: Governs the Supreme Court’s discretion in granting special leave to appeal.
- Charitable and Hindu Religious Institutions and Endowments Act, 1987: State law regulating temple and trust management, subject to constitutional limits.
Implications of the Judgment
Protection of Religious Institutions
The ruling affirms that institutions with established custodial authority cannot be subjected to arbitrary administrative control.
Judicial Restraint and Finality
By refusing to interfere with the High Court’s reasoning, the Supreme Court reinforced the principle of finality and non-interference in factual adjudication unless warranted.
Clarification of Legal Boundaries
The decision makes clear that statutory power must yield to constitutional rights when the two come into conflict.
Broader Impact
- Strengthens Article 26 jurisprudence by affirming the primacy of religious freedom and self-management.
- Sets a clear precedent for other religious institutions resisting state encroachment.
- Reinforces the idea that historical and spiritual ties between institutions matter in determining rightful administration.
- Encourages state authorities to respect constitutional norms while invoking powers under endowment laws.
Conclusion
By refusing to overturn the Andhra Pradesh High Court's judgment, the Supreme Court has underscored the primacy of constitutional rights over statutory authority in matters of religious governance. The ruling offers important clarity on the permissible scope of state involvement in religious institutions, affirming that unless there is proven misconduct, the state must defer to established religious authority. This decision strengthens the framework of religious autonomy in India’s secular legal structure and protects the right of religious denominations to manage their institutions in accordance with tradition and constitutional law.
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