Situs of trust administration determines territorial jurisdiction for seeking sale permission under Section 7 of the Act.

The Plaintiff, a public charitable trust registered under the Indian Trusts Act, 1882, and the Charitable & Religious Trusts Act, 1920 ("the Act"), is headquartered and administered in New Delhi

The Trust owns immovable property (office spaces) in Thane, Maharashtra, which has fallen into disrepair and is no longer leasing-worthy

Seeking to fulfill the Trust’s objects, the Plaintiff filed a suit under Section 7 of the Act for judicial permission to sell the Thane property to an interested purchaser for ₹3,54,89,000/-

The court raised a preliminary issue regarding its territorial jurisdiction to grant such permission given that the physical asset is located outside Delhi

Whether the Delhi High Court has the territorial jurisdiction to entertain a petition under Section 7 of the Charitable & Religious Trusts Act, 1920, for the sale of trust property situated in another state

The court primarily applied Section 7(1) of the Charitable & Religious Trusts Act, 1920, which stipulates that a petition for "opinion, advice or direction" must be filed in the court within whose limits a "substantial part of the subject-matter of the trust is situate"

It applied the principle that different expressions in a statute—specifically "subject-matter of the trust" versus "trust property"—carry distinct meanings

The court further relied on the parens patriae jurisdiction of the court regarding charitable trusts (Executive Officer, Arthanareswarar Temple v. R. Sathyamoorthy)

The court further relied on the "territorial nexus" doctrine established by the Supreme Court in State of Bihar v. Sm. Charusila Dasi and State of Bihar v. Bhabapritananda, which holds that trust administration is governed by the place where the trust is situated or administered

The court reasoned that "subject-matter of the trust" is broader than "trust property". While the latter refers to physical assets, the former encompasses the administrative and management framework.

Since the Plaintiff Trust’s principal office and decision-making authority are in New Delhi, the court determined that the "substantial part" of the trust’s administration—and thus its subject-matter—is located in Delhi.

The court noted that the decision to alienate property is an internal administrative matter involving the parens patriae supervision of the court where the trustees function.

Citing Administrator of Shringeri Math v. Charity Commissioner, the court observed that tying jurisdiction solely to the physical location of assets would lead to practical difficulties and conflicting decisions for trusts with multi-state properties.

Furthermore, the court emphasized that the beneficiaries' right to proper administration is ordinarily enforced at the place of administration.

It concluded that the physical location of property in Maharashtra does not denude the Delhi High Court of its supervisory jurisdiction under Section 7 of the Act, as the trust's administrative seat creates a sufficient territorial nexus.

The matter was listed for further proceedings on May 25, 2026.