Madras High Court Reins In State Overreach In Use Of Temple Funds

Introduction

In an important judgment reaffirming the autonomy of religious institutions, the Madras High Court has held that the State cannot unilaterally deploy temple funds for development or upgradation projects without the approval and involvement of the temple trustees. The Court ruled that the government has no authority to independently envision or impose projects on temples by using their funds, particularly under the framework of the Hindu Religious and Charitable Endowments (HR&CE) Act.

Contents

Introduction Background Of The Case Issues Before The Court Role Of Trustees Under HR&CE Law State’s Limited Supervisory Role No Unilateral Deployment Of Temple Funds Protection Of Religious Autonomy Significance Of The Ruling Impact On HR&CE Governance Conclusion

The ruling, delivered by a Division Bench of Justice Anita Sumanth and Justice C. Kumarappan, strengthens the principle that temple administration and financial decision-making must remain rooted in the statutory role of trustees and not be overridden by executive action.

Background Of The Case

The case arose from a challenge to a Government Order issued by the State of Tamil Nadu, through the Hindu Religious and Charitable Endowments Department, proposing to undertake civil works for the development and upgradation of a temple using temple funds. The State sought to justify the project as being in the interest of devotees and aimed at improving temple infrastructure.

However, the temple trustees objected to the Government Order, arguing that the State had acted unilaterally without consulting or obtaining the consent of the trustees who are legally entrusted with the administration of the temple and its finances. According to the trustees, such an action amounted to excessive state interference in temple affairs and violated the statutory scheme of the HR&CE Act.

The matter eventually reached the Madurai Bench of the Madras High Court.

Issues Before The Court

The Division Bench considered the following key issues:

Whether the State can unilaterally plan and execute development projects for temples using temple funds
Whether such action violates the statutory powers and duties of temple trustees under the HR&CE Act
The extent of the State’s role in temple administration and financial management

Role Of Trustees Under HR&CE Law

The Court examined the statutory framework governing Hindu temples, particularly the provisions of the HR&CE Act, which vest the administration of temple affairs, properties, and finances primarily in the trustees. Trustees are legally obligated to manage temple funds in accordance with the objects of the institution, religious customs, and the interests of devotees.

The Bench observed that while the State, through the HR&CE Department, has a supervisory role to ensure proper administration and prevent mismanagement, such oversight does not extend to substituting the trustees’ decision-making authority.

State’s Limited Supervisory Role

The Madras High Court made it clear that the State’s role is supervisory and regulatory, not managerial. The Court noted that the government cannot assume the role of a planner or project architect for temples, particularly when it involves the utilisation of temple funds.

The Bench observed that allowing the State to unilaterally deploy temple funds would undermine the statutory autonomy of religious institutions and blur the distinction between regulation and control.

According to the Court, even if a project is framed as beneficial or intended for temple upgradation, the decision must emanate from the trustees, who are best placed to assess the needs, priorities, and financial capacity of the temple.

No Unilateral Deployment Of Temple Funds

Setting aside the impugned Government Order, the Court categorically held that the State cannot declare or implement projects using temple funds without prior consultation and approval of the trustees.

The Bench emphasised that temple funds are not public revenue at the unfettered disposal of the government. Instead, they are trust funds meant exclusively for the religious and charitable purposes of the temple.

The Court observed that any expenditure of temple funds must strictly conform to statutory requirements, temple customs, and trustee resolutions.

Protection Of Religious Autonomy

The judgment reinforces the constitutional principle of religious autonomy under Articles 25 and 26 of the Constitution of India, which guarantee freedom of religion and the right of religious denominations to manage their own affairs in matters of religion.

While acknowledging that the State can regulate secular aspects of temple administration, the Court cautioned against excessive governmental intrusion that effectively strips trustees of their lawful authority.

Significance Of The Ruling

This ruling has wide implications for temple administration in Tamil Nadu and other states with similar regulatory frameworks. It draws a clear line between permissible state supervision and impermissible control over religious institutions.

The judgment is particularly significant in the context of increasing state-led temple development initiatives, as it mandates trustee participation and consent as a precondition for the utilisation of temple funds.

Impact On HR&CE Governance

The decision serves as a reminder to the HR&CE Department that its powers must be exercised within statutory limits. Any attempt to bypass trustees or impose projects without their approval is liable to be struck down as arbitrary and ultra vires the Act.

The Court’s reasoning may also influence future challenges against government orders involving diversion or utilisation of temple funds without adequate stakeholder consultation.

Conclusion

By holding that the State cannot unilaterally deploy temple funds without the approval of trustees, the Madras High Court has reaffirmed the central role of trustees in temple administration and protected the financial autonomy of religious institutions.

The judgment underscores that temples are not mere administrative units of the State but independent religious trusts governed by law. Any development or upgradation project must therefore be rooted in trustee consent, statutory compliance, and respect for religious autonomy.

This ruling strengthens the balance between state regulation and religious self-governance, ensuring that temple funds are utilised only in accordance with law and the will of those entrusted with their management.