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, 4The petitioner relied on the temple’s Thozhil Attavanai and Suthanthira Attavanai, which describe the Jeeyar’s religious and administrative role
p. 7The Court considered the matter alongside a contemporaneous petition concerning the vacancy at Srirangam
pp. 3–502Issues
i.Whether the long-standing vacancy in the office of Jeeyar at Kallalagar Temple should be addressed by restoring the customary institution
pp. 4–5ii.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. 603Law 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. 5It 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. 4It 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. 6The Court further stated that devotees have a stakeholder interest in upholding temple customs and usages, grounded in Article 25 of the Constitution.
p. 7Provisions 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, 7Since 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. 605Holding
The writ petition was disposed of without a time-bound mandamus.
p. 8The 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. 8It 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. 8No costs were ordered.
p. 8Original Court PDF
R.SathyanarayananvsThe Secretary to Government
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