Absent a recorded festival procedure, mandamus cannot compel Fit Person appointment or festival control.

The petitioner sought a writ of mandamus directing the District Collector and HR&CE authorities to appoint a Fit Person to administer four temples at Surakundu Village, Melur Taluk, and to conduct the Purattasi festival through that Fit Person. He also sought restraint against respondents 6–10 from collecting temple funds or receiving the first honour, directions to hand over the temple accounts, records and village-chest key, and police protection for the festival.

The petitioner claimed that the temples were exclusively associated with five traditional Karais of the village and alleged that a sixth Karai belonging to the Scheduled Caste community had been excluded from the festival.

Respondents 6–10 disputed the petitioner’s entitlement, asserting that he belonged to the same Karai as the sixth respondent and had been removed from his former position because of alleged misuse and failure to account for temple funds.

The temples were treated as non-listed temples falling within the purview of the HR&CE Department, and no recorded procedure governing the festival was shown to exist.

Whether the Court should issue a writ of mandamus directing the HR&CE authorities to appoint a Fit Person, regulate the conduct of the temple festival, prevent respondents 6–10 from collecting funds or receiving honours, and provide consequential administrative and police directions

Whether the competing claims concerning the right to receive the first honour and other customary privileges could be adjudicated in the writ proceedings

Whether the petitioner or the private respondents should pursue statutory remedies under Sections 63 and 64 of the Hindu Religious and Charitable Endowments Act, 1959

The Court exercised its jurisdiction under Article 226 of the Constitution but held that mandamus could not be granted where the administration and festival procedure of the non-listed temples were not governed by any recorded or established procedure.

Section 64 of the Hindu Religious and Charitable Endowments Act, 1959 provides the statutory mechanism for framing an appropriate scheme for the management of a religious institution and its festivals.

Section 63 of the Act provides the appropriate forum for resolving questions concerning customary rights, including the right to receive the first honour.

The Court found that the petition involved disputed questions regarding the village Karais, the petitioner’s former status, the participation of the Scheduled Caste community, the collection and accounting of temple funds, the festival date, and entitlement to honours.

Since the temples were non-listed but within the HR&CE Department’s jurisdiction and there was no recorded procedure governing the festival, the Court considered it inappropriate to create an ad hoc administrative arrangement or grant the extensive mandamus sought.

Instead, it directed the parties to use the statutory mechanisms: the petitioner could seek framing of a management and festival scheme under Section 64, while claims relating to first honours could be raised before the Joint Commissioner under Section 63.

The petitioner was granted liberty to approach the HR&CE Department under Section 64 for framing an appropriate scheme, and the private parties were permitted to participate in those proceedings. All parties were also granted liberty to approach the Joint Commissioner under Section 63 regarding recognition of the first right and first honours.