01Facts
The Executive Officer of Arulmighu Mutharamman Thirukovil challenged the Commissioner of Land Administration’s order dated 22 July 2026, which directed mutation of the revenue records in the name of Sree Narguna Sundara Vinayakar Temple, represented by its hereditary trustee, the fifth respondent.
p. 1 · ¶ 1The petitioner sought revenue entries describing the land as “Nathan-Punjai” and a patta in the temple’s name.
p. 1The fifth respondent objected to maintainability, while the petitioner relied on a circular based on a Supreme Court judgment concerning the recording of a deity’s name in revenue records.
pp. 2–3 · ¶ 3–502Issues
i.1. Whether the petitioner could maintain the writ petition concerning the revenue records of Sree Narguna Sundara Vinayagar Temple, notwithstanding the fifth respondent’s objection.
p. 3 · ¶ 6ii.2. Whether the revenue records could identify the deity through its hereditary trustee, or should record the deity’s name alone.
pp. 3–4 · ¶ 5, 7–8iii.3. Whether the land could be classified as “Natham Private” in the revenue records.
p. 5 · ¶ 903Law Applied
Under Article 226 of the Constitution, the High Court may exercise jurisdiction in a matter concerning a deity, which is treated as a minor and may be protected through the Court’s parens patriae jurisdiction.
p. 3 · ¶ 6Applying the Supreme Court’s judgment in Civil Appeal No. 4850 of 2021, the Court stated that revenue records should contain the deity’s name, not the name of its manager or priest; a poojari performing religious functions and cultivating the land may be named in the remarks column.
p. 3 · ¶ 5The Supreme Court had also contemplated executive instructions supplementing the relevant statute and rules.
p. 3, 5 · ¶ 5, 10The Court further held that “Natham Private” was not a classification recognised under the Revenue Standing Order.
p. 5 · ¶ 904Reasoning
The Court rejected the maintainability objection because the petitioner represented a deity and the Court could protect the deity’s interests through its parens patriae jurisdiction.
p. 3 · ¶ 6It held that the Commissioner’s direction to record the deity’s name as represented by its hereditary trustee conflicted with the Supreme Court’s rule that the deity alone should be named in the revenue records.
pp. 4–5 · ¶ 7–9The absence of executive instructions from the Revenue Department did not displace that rule, which the Court treated as binding law.
p. 4 · ¶ 7It also rejected the “Natham Private” classification as unrecognised under the Revenue Standing Order.
p. 5 · ¶ 905Holding
The writ petition was disposed of with a direction that the revenue records record only the name of Sree Narguna Sundara Vinayagar Balasubramaniar, and that the land be classified as “natham”.
p. 5 · ¶ 9The Court directed the Secretary, Revenue and Disaster Management Department, to issue necessary instructions and the revenue authorities to make corrections consistent with paragraph 27 of the Supreme Court judgment.
p. 5 · ¶ 10No costs were ordered, and the connected miscellaneous petition was closed.
p. 5 · ¶ 9Original Court PDF
The Executive officer,vsThe Commissioner of Land Administration,
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