MP High Court: Government Cannot Interfere in Management of Private Temples; Collector’s Name Cannot Be Recorded as Manager in Revenue Records
The Madhya Pradesh High Court has reaffirmed the legal distinction between private and government-managed temples, holding that the State has no authority to interfere in the administration of a private temple. In a significant judgment delivered on 16 June 2026 in Ramakant Tiwari v. State of Madhya Pradesh (W.P. No. 1737 of 2011), the Court ruled that the Collector cannot be shown as the manager or administrator of a private temple in revenue records merely because land attached to the temple is entered in the name of the deity.
The dispute arose over agricultural land dedicated to a private temple, where revenue authorities had recorded the Collector as the administrator. The petitioner challenged the revenue entries and contended that the temple was a private religious institution managed by the family and that the State had no legal role in its affairs. The petitioner also sought correction of revenue records and removal of the Collector’s name so that the property could be lawfully dealt with.
Examining historical revenue records, the High Court noted that the land had long been recorded in the name of the deity, establishing that it was temple property attached to a private religious endowment. The Court observed that under settled Hindu law, the deity is a juristic person capable of owning property, while the pujari or shebait merely manages the affairs of the deity and does not become the owner of the property.
Relying heavily on the Supreme Court’s landmark judgment in State of Madhya Pradesh v. Pujari Utthan Avam Kalyan Samiti (2021), the High Court emphasized that after the repeal of earlier land laws, the rights of pujaris over temple lands are managerial and custodial in nature and cannot be equated with ownership. At the same time, the Court clarified that this legal position does not authorize the government to assume management of private temples or appoint itself as their administrator.
The High Court referred to an earlier coordinate Bench decision, reiterating that the State’s role is confined to government temples or temples specifically governed by statutory provisions. In the case of a private temple, the government has no authority to appoint a pujari, create a management committee, or direct that the Collector’s name be entered as manager or trustee in revenue records. Revenue entries, the Court held, should ordinarily remain in the name of the deity alone.
While protecting the autonomy of private temples, the Court also recognized that temple property cannot be misused. Since a deity is regarded as a perpetual juristic entity, any allegation of mismanagement or illegal alienation of temple property must be addressed through appropriate civil proceedings initiated by worshippers or other interested persons, rather than by unilateral executive action of the State.
The judgment further reinforces the constitutional protection available to private religious institutions under Articles 25 and 26 of the Constitution by limiting executive interference in their internal management. At the same time, it preserves judicial oversight where disputes regarding temple property or administration arise, ensuring that such controversies are resolved by competent courts rather than revenue authorities.
The ruling is expected to have wider implications across Madhya Pradesh, particularly in disputes involving private temples where revenue records continue to reflect the Collector or other government officials as managers or administrators. The decision makes it clear that government authorities cannot assume control over private temples merely because temple lands are reflected in revenue records, and that ownership must continue to vest in the deity, with management remaining subject to the applicable principles of religious endowment law and judicial scrutiny.
MP High Court: State Has No Role in Managing Private Temples, Collector Cannot Be Named Manager in Revenue Records. Govt Cannot Interfere In Management Of Private Temples: MP High Court. The Madhya Pradesh High Court has made it clear that the government cannot interfere in the management of a private temple. Madhya Pradesh High Court: Ramakant Tiwari vs The State Of Madhya Pradesh on 16 June, 2026 WRIT PETITION No. 1737 of 2011. Supreme Court of India: The State Of Madhya Pradesh vs Pujari Utthan Avam Kalyan Samiti on 6 September, 2021 CIVIL APPEAL NO. 4850 OF 2021 (ARISING OUT OF SLP (CIVIL) NO. 33675 OF 2017)
Supreme Court of India: The State Of Madhya Pradesh vs Pujari Utthan Avam Kalyan Samiti on 6 September, 2021 CIVIL APPEAL NO. 4850 OF 2021 (ARISING OUT OF SLP (CIVIL) NO. 33675 OF 2017)
The State Of Madhya Pradesh vs Pujari Utthan Avam Kalyan Samiti on 6 September, 2021 CIVIL AP
Madhya Pradesh High Court: Ramakant Tiwari vs The State Of Madhya Pradesh on 16 June, 2026 WRIT PETITION No. 1737 of 2011
Ramakant Tiwari vs The State Of Madhya Pradesh on 16 June, 2026 WRIT PETITION No. 1737 of 2011
