Shifting Idols From Dilapidated Temple To Ensure Worship Is Not Misconduct By Priest: Madhya Pradesh High Court
The dispute arose after local residents complained that the petitioners had mismanaged the temple property and that the temple of Radha Gopalji was no longer standing.
The Madhya Pradesh High Court has held that shifting idols from a dilapidated temple to a nearby functional temple to ensure uninterrupted worship cannot be treated as misconduct or abandonment of duty by priests.
A Bench of Justice Milind Ramesh Phadke held, “The contention of the respondents that shifting of the idols from the collapsed structure to another temple amounted to dereliction of duty cannot be accepted. The preservation of the idols and continuation of worship constitute the essence of temple management and religious administration. ”
The Court set aside the orders of the Collector, Commissioner and Upper Chief Secretary directing their removal as priests of the Radha Gopalji Shri Ram Jankiji Temple at Kolaras in Shivpuri district.
Senior Advocate V K Bhardwaj appeared for the Petitioner and GA Shiraz Qureshi appeared for the Respondent.
The dispute arose after local residents complained that the petitioners had mismanaged the temple property and that the temple of Radha Gopalji was no longer standing.
The petitioners explained that there were historically two temples—Radha Gopalji and Ram Jankiji. They submitted that the Radha Gopalji temple had become extremely old, severely dilapidated and had ultimately collapsed due to the passage of time. In 1972, the idols were shifted to the nearby Shri Ram Jankiji Temple to preserve their sanctity and ensure uninterrupted daily worship and religious rituals.
Pursuant to the directions of the Sub-Divisional Officer (SDO), the Superintendent Land Manager conducted a spot inspection and categorically reported that the original temple structure had collapsed because of natural deterioration. The inquiry further established that the idols had been shifted to the nearby Shri Ram Jankiji Temple, where regular worship and religious ceremonies continued uninterrupted under the supervision of the petitioners.
Significantly, the inquiry did not find any financial irregularity, embezzlement, misappropriation of temple income, encroachment upon temple land or misuse of temple property by the petitioners. It also recorded that the petitioners had repeatedly requested the State authorities to provide financial assistance for reconstruction of the collapsed temple.
Relying on the inquiry report, the SDO dropped the removal proceedings and recommended that the competent authorities provide funds for reconstruction of the temple. However, the Collector reversed the order and initiated steps to remove the petitioners, which was later affirmed by the Commissioner and the Upper Chief Secretary.
Setting aside those orders, the High Court observed that the Collector reversed the well-reasoned findings of the SDO without assigning any cogent reason for discarding the inquiry report and without referring to any independent material demonstrating negligence, misconduct or misappropriation on the part of the petitioners.
The Court held that "when an ancient structure becomes unsafe and unfit for worship, the act of transferring the idols to a nearby functional temple to ensure uninterrupted performance of religious rituals cannot be treated as misconduct or abandonment of duty."
Rather, the Court said, "such conduct reflects diligence and devotion on the part of the petitioners in safeguarding the interests of the deity and the religious sentiments of the devotees."
The High Court also noted that the inquiry report found no instance of financial irregularity or misuse of temple property and that the material on record, including a Panchnama executed by villagers and a certificate issued by the Nagar Panchayat, indicated that the petitioners had continuously discharged their duties as priests.
Holding that there was no proven misconduct, the Court ruled that the drastic consequence of removing the petitioners from the office of priest could not have been ordered. It consequently quashed the orders and restored the SDO's order dropping the proceedings against the petitioners.
Cause Title: Narayan Das & Ors. v. State Of M.P. & Ors., [2026:MPHC-GWL:21276]
Appearance:
Petitioners: Senior Advocate V K Bhardwaj, Advocate Anand V. Bhardwaj
Respondents: GA Shiraz Qureshi
