Madras High Court
Administrative and Public LawConstitutional Law

HR&CE Must Issue an NOC for Village Drama on Temple-Controlled Land Upon Request

R.Rajkumar vs The State of Tamilnadu

Madras High CourtJUDGMENT: September 28, 20263 MIN READSOURCE JUDGMENT
HR&CE Must Issue an NOC for Village Drama on Temple-Controlled Land Upon Request. R.Rajkumar vs The State of Tamilnadu. Madras High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner sought permission and police protection to stage the Sree Magamayee @ Chinnakaruppu Periyakaruppu drama on 29 September 2026 at a permanent stage near Sree Thirumeni Ayyanar Temple in Kunapanenthal Village

Source reference: para. 1

In an earlier writ petition concerning the same date’s Church festival, the Court had directed the revenue authorities to consider the respective festival requests and, if permission was granted, the police to provide protection for both events

Source reference: paras. 2–3

The Tahsildar subsequently allotted the Church event the 6:00 p.m.–9:30 p.m. slot and the Hindu community’s procession and drama the period from 10:00 p.m., but required the petitioner to obtain a court order for the drama because of a dispute concerning Survey No. 135/9

Source reference: para. 4

The petitioner relied on earlier proceedings concerning that land, which was described as village poramboke land under HR&CE control with a temple situated on it; he also stated that a challenge to the Tahsildar’s 2021 order remained pending without a stay

Source reference: paras. 5–8

The Court suo motu impleaded the local HR&CE Inspector.

Source reference: para. 9

The State submitted that an HR&CE no-objection certificate (NOC) would enable permission for the drama and that police protection could follow; it also raised concerns about prior disputes and FIRs between the groups

Source reference: paras. 9–11
02

Issues

Whether the petitioner could be permitted to conduct the drama on Survey No. 135/9, subject to obtaining an NOC from the HR&CE authority and permission from the Tahsildar.

Source reference: paras. 9–10, 13(i)–(ii)

Whether the police should provide protection for the drama and the Church festival and procession scheduled for the same date.

Source reference: paras. 3, 11, 13(iii)
03

Law Applied

The petition invoked the High Court’s jurisdiction under Article 226 of the Constitution to seek mandamus.

Source reference: no citation

The Court referred to its earlier order in W.P. Crl. (MD) No. 5248 of 2026, which required the revenue authorities to consider the event requests and contemplated police protection for both communities if permission was granted.

Source reference: para. 3

It also noted the Division Bench’s direction in S. Michael v. The District Collector, Sivagangai District, W.P. (MD) No. 13526 of 2021, that the Tahsildar consider the petitioner’s representation in accordance with the applicable rules and regulations.

Source reference: para. 6

The order lays down no further general statutory test or substantive legal doctrine; it resolves the request through the identified administrative steps and protection arrangements.

Source reference: no citation
04

Reasoning

The Court treated the stage as intended for public use but recognised that the land was associated with a temple under HR&CE control and that the Tahsildar had required further authority for the drama.

Source reference: paras. 7–9

In light of the State’s submission that an HR&CE NOC would permit the matter to proceed, the Court directed the HR&CE authority to issue the NOC upon receiving the petitioner’s request, after which the Tahsildar was to permit the drama.

Source reference: paras. 10, 13(i)–(ii)

Given the reported disputes, the Court also recorded a direction for the petitioner to file an undertaking before the police that he would not cause disorder or commit an offence.

Source reference: paras. 11–12

It then directed police protection for both events, rather than allowing the dispute to prevent their peaceful conduct.

Source reference: para. 13(iii)
05

Holding

The writ petition was disposed of with directions that the HR&CE authority issue an NOC on receipt of the petitioner’s request; the Tahsildar permit the drama on 29 September 2026 after receiving the NOC; and the police provide adequate protection, free of cost, to the petitioner’s group and the Christian community for the events scheduled that day.

The petitioner was also directed to file an undertaking before the police.

Source reference: para. 12
Madras High Court

Original Court PDF

R.RajkumarvsThe State of Tamilnadu

Madras High Court · September 28, 2026

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