Court directs expeditious resolution of Sri Krishna Jayanti festival dispute at Arulmigu Sri Prasanna Venkatesa Perumal Temple under Tamil Nadu HR&CE Act, 1959; police to maintain law and order only
Chennai, October 1, 2026: The Madras High Court delivered a significant ruling in the matter concerning the conduct of the 35th year Sri Krishna Jayanti festival at the Arulmigu Sri Prasanna Venkatesa Perumal Temple in Venkatapuram village, Kancheepuram District. The writ petition filed by Thangamani Rajamanikkam challenged an order refusing permission to conduct the festival due to disputes between rival groups claiming rights over the temple's management and ceremonies.
Justice D. Bharatha Chakravarthy, presiding over W.P.No.40271 of 2026, clarified the role of administrative and law enforcement authorities in such religious disputes. The court held that questions relating to who is entitled to manage the temple, what ceremonies should be conducted, and whether any traditional or customary rights exist fall exclusively under the jurisdiction of the Joint Commissioner of the Hindu Religious and Charitable Endowments (HR&CE) Department as per Section 63 of the Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959.
The court noted that the Assistant Commissioner of HR&CE had inspected the temple but expressed inability to resolve the dispute due to competing claims. Importantly, the judge emphasized that such matters must be adjudicated based on merits without any reference to caste considerations, dismissing caste-based objections as irrelevant to the legal determination of rights. The High Court directed that any party claiming rights in the temple's management or festival conduct should file an application with the Joint Commissioner, who must issue notices to both sides and decide the dispute expeditiously, within four months of application receipt.
Regarding the role of the district administration and police, the court reiterated that their function is limited strictly to maintaining law and order and does not extend to adjudicating civil or religious rights. This distinction was underscored in light of previous orders that had directed law enforcement to prevent disruption but not to decide the underlying dispute.
Additionally, the court expressed concern over the dilapidated condition of the temple structure as reported by the Assistant Commissioner. It directed the authorities to carry out a proper inspection and take necessary protective measures to safeguard the temple's physical integrity.
This ruling provides a clear procedural roadmap for resolving temple festival disputes, ensuring that the HR&CE Department's statutory mechanism is the appropriate forum for such claims, while law enforcement maintains peace and order. The decision is poised to prevent misuse of police powers in religious management disputes and uphold legal sanctity in temple administration.
Bottom Line:
Temple festival dispute - Where rival groups claim rights to manage temple and conduct festival ceremonies, such issues as to management, customary ceremonies and traditional rights fall within Section 63 of the Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959 and are to be decided by the Joint Commissioner, without reference to caste considerations; police authorities are confined to maintenance of law and order.
Statutory provision(s):
Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959, Section 63; Constitution of India, Article 226
