Himachal Pradesh High Court Sets Precedent for Temple Fund Utilization

Court Mandates Strict Guidelines for Temple Fund Use, Upholds Religious and Economic Integrity
In a landmark judgment, the Himachal Pradesh High Court has set forth stringent guidelines regarding the utilization of temple funds, emphasizing their exclusive use for religious and dharmic purposes. The decision was handed down by a Division Bench comprising Mr. Vivek Singh Thakur and Mr. Rakesh Kainthla, in the case of Kashmir Chand Shadyal v. State of H.P. The judgment, dated October 10, 2025, scrutinizes the economic and financial activities associated with Hindu public religious institutions under the Himachal Pradesh Hindu Public Religious Institutions and Charitable Endowments Act, 1984.
The petitioner, Kashmir Chand Shadyal, invoked Article 226 of the Constitution of India, seeking a writ of mandamus to ensure compliance with specific provisions of the Act, particularly those related to budgeting, accounting, and expenditure.
The court underscored the necessity of using temple funds strictly for dharmic purposes, such as temple maintenance and propagation of Hindu religious values. The judgment prohibits the use of these funds for state welfare schemes, construction unrelated to temple purposes, private business investments, and funding non-Hindu religious events.
In its analysis, the court elaborated on the historical and contemporary role of Hindu temples, maths, and endowments in societal reform and development. These institutions have traditionally been centers for education, social welfare, cultural preservation, and the promotion of Hindu values, thereby acting as catalysts for societal transformation.
The judgment mandates that temples must publicly display their accounts, maintain proper financial records, and undergo annual audits to ensure transparency and accountability. Trustees will be held personally liable for any misuse of temple funds, with provisions for recovering such funds from them.
The court's directives aim to safeguard the sanctity of temple funds, ensuring they are used in alignment with the religious and cultural ethos of Hinduism. The decision is expected to foster greater trust among devotees, reinforcing the role of temples as vital institutions in the spiritual and social fabric of the community.
This ruling is anticipated to have far-reaching implications, setting a precedent for the governance and management of temple funds not only in Himachal Pradesh but potentially across other states with similar legal frameworks.
Bottom Line:
Regulation of Hindu Public Religious Institutions and Charitable Endowments under the Himachal Pradesh Hindu Public Religious Institutions and Charitable Endowments Act, 1984.
Statutory provision(s): Constitution of India, Article 25; Himachal Pradesh Hindu Public Religious Institutions and Charitable Endowments Act, 1984, Sections 17, 22, and 23
Kashmir Chand Shadyal v. State of H.P., (Himachal Pradesh)(DB) : Law Finder Doc Id # 2794790