Trust - Property once validly dedicated for public charitable purposes : Distant relatives of settlor lack locus standi to challenge

Patna High Court Upholds Construction of Panchayat Sarkar Bhavan on Trust Land. Court Denies Distant Relative's Claim Against Public Use of Hanuman Pustakalaya Property

In a significant ruling, the Patna High Court has dismissed a writ petition challenging the construction of a Panchayat Sarkar Bhavan on land belonging to Hanuman Pustakalaya, a public charitable trust, in Muzaffarpur. The petition was filed by Ranjan Kumar, a distant relative of the original settlor of the trust, who claimed that the land was meant exclusively for library purposes as per the trust deed executed by his ancestor.

Justice Anil Kumar Sinha presided over the case, which revolved around the legal standing of distant relatives to contest the use of trust property. The court ruled that once property is dedicated to a public charitable trust, ownership by the settlor and their heirs is extinguished, and the property vests in the trustees for public benefit. The court found that the petitioner, being a distant relative, lacked the legal standing to challenge the use of the land, especially in the absence of a functioning trustee body.

The judgment highlights that the construction of the Panchayat Sarkar Bhavan aligns with the trust's charitable objectives. The court noted that the structure serves as a public office for local governance, thus furthering public benefit in accordance with the trust's spirit. The ruling also addressed procedural aspects, confirming that the construction was approved in a Gram Sabha meeting and adhered to the guidelines of the Panchayati Raj Department.

While the court dismissed the petition, it allowed for future trustees to seek compensation for the use of trust land if deemed necessary, once a duly constituted trustee body is in place.

Bottom Line:

Trust property - Distant relatives of the settlor have no locus standi to challenge the use of trust property once validly dedicated for public charitable purposes. Public office serving local self-governance institutions may be considered in harmony with the broad objectives of a public charitable trust.

Statutory provision(s): Trust property law, Public charitable trust regulations, Panchayati Raj guidelines.

Ranjan Kumar v. State of Bihar, (Patna) : Law Finder Doc Id # 2804027