Pujari Not Landowner, Only Manager Of Deity’s Property: Chhattisgarh High Court
The petition challenged a 2015 Board of Revenue order affirming the Vindhyavasini Mandir Trust Samiti as the lawful managing body of the Vindhyavasini Temple and its properties.
Justice Bibhu Datta Guru, Chhattisgarh High Court
The Chhattisgarh High Court has held that a pujari (temple priest) cannot claim ownership or proprietary rights over temple property, reaffirming that their role is limited to managing religious duties on behalf of the deity.
A writ petition was filed by the Shri Vindhyavasini Maa Bilaimata Pujari Parishad Committee challenging a 2015 order of the Board of Revenue (BoD), reaffirming that the Vindhyavasini Mandir Trust Samiti is the lawful managing body of the temple and its properties.
A Bench of Justice Bibhu Datta Guru held, “The Pujari is only a grantee to manage the property of the deity and such grant can be reassumed if the Pujari fails to do the task assigned to him i.e. to offer prayers. He cannot be thus treated as a Bhumiswami. It is also the trite law that the Pujari does not have any right in the land and his status is only that of a manager. Rights of pujari do not stand on the same footing as that of Kashtkar Mourushi in the ordinary sense who are entitled to all rights including the right to sell or mortgage.”
Advocate Vimlesh Bajpai appeared for the Petitioner and Advocate Anand Mohan Tiwari appeared for the respondent.
Background
The petition arose from a long-standing dispute over the management and proprietary rights of the Vindhyavasini Temple at Dhamtari, Chhattisgarh. The petitioner sought to overturn an order passed by the Board of Revenue on October 3, 2015, which had rejected their plea to include the name of one Ashwani Dubey in the records of the temple trust.
Initially, in 2003, the Tahsildar had directed the inclusion of Dubey’s name in the trust’s records. However, this order was overturned by the Sub-Divisional Officer (SDO), Dhamtari, and upheld in subsequent appeals before the Additional Commissioner and the Board of Revenue.
Observations
The High Court, after examining the facts and legal precedents, noted that the temple trust had been a registered institution since January 23, 1974, and was entrusted with managing the temple and its assets. The Court referenced a Civil Judge’s decree from 1989, which had already declared that the trust had lawful authority over the temple and its property, and that priests had no hereditary or proprietary claim.
The Court reiterated that a pujari has no ownership rights, cannot claim possession over temple lands, and cannot treat temple property as personal or ancestral. Any such claim would amount to mismanagement, making the pujari unfit to remain in service. It added, “It is pertinent to mention here that if the Pujari claims proprietary rights over the property of the temple, it is an act of mismanagement and he is not fit to remain in possession or to continue as a Pujari.”
The Court also found that the present petitioner was not a party in the original proceedings before the Board of Revenue. The revision had been filed by a different entity. The Court held that the current petitioner had no locus standi to file the writ petition and challenge the BoD’s decision.
The High Court found no merit in the petition and dismissed it, stating that the Board of Revenue had passed a well-reasoned and legally sound order.
Cause Title: Shri Vindhyavasini Maa Bilaimata Pujari Parishad Committee v. Vindhyavasini Mandir Trust Samiti, [2025:CGHC:29861]
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