Madras High CourtReligious and Personal LawAdministrative and Public Law

After 80-Year Vacancy, Madras HC Asks Three Religious Leaders To Choose Kallalagar Temple Jeeyar

R.Sathyanarayananv.The Secretary to Government

After 80-Year Vacancy, Madras HC Asks Three Religious Leaders To Choose Kallalagar Temple Jeeyar. R.Sathyanarayanan vs The Secretary to Government. Madras High Court. LawLens
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In brief

The question

Whether the long-standing vacancy in the office of Jeeyar at Kallalagar Temple should be addressed by restoring the customary institution

The court held

The writ petition was disposed of without a time-bound mandamus.

It also directed

The Court requested the Jeeyars of Thirukurungudi and Alwarthirunagari, together with Periya Nambigal Swamy, to choose the next Pontiff of Sri Ramanuja Jeeyar Mutt, Kallalagar Temple.

It expressed the hope that the process would be expedited and stated that, once a choice was made, the Department should formally issue proceedings recognising it.

No costs were ordered.

01Facts

The petitioner sought a mandamus directing the authorities to fill the vacant office of Jeeyar associated with Arulmigu Kallalagar Temple, Madurai.

The Department and temple authorities acknowledged that the temple had Jeeyars historically, but that the last incumbent, appointed in 1937, had disappeared around 1946; the office had remained vacant since then

p. 2, 4

The petitioner relied on the temple’s Thozhil Attavanai and Suthanthira Attavanai, which describe the Jeeyar’s religious and administrative role

p. 7

The Court considered the matter alongside a contemporaneous petition concerning the vacancy at Srirangam

pp. 3–5

02Issues

i.Whether the long-standing vacancy in the office of Jeeyar at Kallalagar Temple should be addressed by restoring the customary institution

pp. 4–5

ii.Whether, in the absence of sthalattars or an identifiable successor-nomination process, the next Jeeyar could be chosen by heads of kindred religious institutions

p. 6

03Law Applied

The Court relied on the Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959, including Section 60, which requires the jurisdictional authority to make temporary arrangements when a vacancy arises in the office of a Madathipathi.

p. 5

It applied the principle that established religious custom should be followed and that departures from custom should be corrected by restoring it, relying on Marthanda Varma v. State of Kerala, (2021) 1 SCC 225.

p. 4

It also relied on Vidyapurna Tirthaswami v. Vidyanidhi Tirthaswami, ILR 27 Mad 435, for the proposition that, where succession cannot be determined through the usual channel, nomination may rest with the head of a kindred institution; that principle was endorsed in Sri Mahalinga Thambiran Swamigal v. Arulnandhi Thambiran Swamigal, (1974) 1 SCC 150.

p. 6

The Court further stated that devotees have a stakeholder interest in upholding temple customs and usages, grounded in Article 25 of the Constitution.

p. 7

Provisions in the judgment · 1 · Linked ones open on LawLens

TAMIL NADU HINDU RELIGIOUS AND CHARITABLE ENDOWMENTS ACT, 1959 Section 60

04Reasoning

The Court treated the Jeeyar’s office as part of the temple’s established religious and administrative tradition, rather than an office whose prolonged vacancy extinguished the custom.

The temple records described the Jeeyar as the paramount authority, responsible for religious and secular administration, and the Court considered restoration consistent with the principle that established usages should be revived.

p. 4, 7

Since Kallalagar Temple had no sthalattars and the Mutt had been headless for decades, the Court applied the kindred-institution approach described in Vidyapurna Tirthaswami and identified religious heads capable of selecting a successor.

p. 6

05Holding

The writ petition was disposed of without a time-bound mandamus.

p. 8

The Court requested the Jeeyars of Thirukurungudi and Alwarthirunagari, together with Periya Nambigal Swamy, to choose the next Pontiff of Sri Ramanuja Jeeyar Mutt, Kallalagar Temple.

p. 8

It expressed the hope that the process would be expedited and stated that, once a choice was made, the Department should formally issue proceedings recognising it.

p. 8

No costs were ordered.

p. 8
Madras High Court

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R.SathyanarayananvsThe Secretary to Government

Madras High Court · October 23, 2026

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