No Pujari can Claim Ownership of a Property owned by Diety, Read HC Judgment

The Madhya Pradesh High Court has ruled that agricultural lands attached to Mandir Ganesh Ji in Ashoknagar district belong to the deity and not to the serving pujari, overturning findings that had favoured continued private control. Allowing the State’s appeal, the Court directed that the temple’s management be vested in the district Collector, reinforcing the legal position that temple property cannot be treated as personal inheritance.

The dispute arose from a civil suit filed through Bhalchandra Rao, who claimed to be the hereditary pujari of the 200 year old temple, said to have been built by Subedar Chimanji. He sought declaration of title and permanent injunction over agricultural lands situated in villages Shadora, Nagukhedi and Piprauli, asserting that the temple was a private family shrine and that its properties were under his lawful management.

While the Trial Court and First Appellate Court upheld the temple’s claim over the property, they also recognised a succession-based right of management in favour of the plaintiff, prompting the State to challenge the decision.

Justice G.S. Ahluwalia clarified the legal position, observing that “Manager or Pujari is the servant of Deity and property of temple belongs to Deity and not Manager/Pujari.” The Court held that even if earlier generations acted as pujari, such status does not confer ownership rights over temple assets. It further noted the absence of evidence showing lawful succession, income records, or proof of expenditure for temple upkeep, and found that personal interest conflicted with the deity’s interest.

Concluding that the temple was vested in the State’s Maufi Aukaf Department, the Court set aside the impugned orders and directed the Collector to assume management.

Case Title: State Of M.P. Through Collector Vs. Mandir Shri Ganeshji Situated And Ors.

Case No.: Second Appeal No. 194 of 2006

Coram: Hon'ble. Justice G. S. Ahluwalia

Advocate for the Petitioner: Adv. Rajendra Jain,

Advocate for the Respondent: Adv. Prashant Sharma,

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