Madras High Court
Administrative and Public LawReligious and Personal Law

Temple management and customary festival rights fall within the HR&CE Joint Commissioner’s Section 63 jurisdiction.

THANGAMANI RAJAMANIKKAM vs THE DISTRICT COLLECTOR

Madras High CourtJUDGMENT: October 01, 20262 MIN READSOURCE JUDGMENT
Temple management and customary festival rights fall within the HR&CE Joint Commissioner’s Section 63 jurisdiction.. THANGAMANI RAJAMANIKKAM vs THE DISTRICT COLLECTOR. Madras High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner sought to quash the Revenue Divisional Officer’s proceedings dated 3 September 2026 and obtain permission to hold the 35th Sri Krishna Jayanthi festival, including a procession, at Arulmigu Sri Prasanna Venkatesa Perumal Temple on 4 October 2026.

Source reference: p. 2

The petitioner asserted that the festival and procession were traditional, while alleging that objections to them arose from caste differences.

Source reference: para. 3, p. 3

In an earlier writ petition filed by the private respondent, the Court had directed the HR&CE Assistant Commissioner to inspect the temple, hear the parties, and determine who was entitled to conduct the festival; the other authorities were to maintain law and order.

Source reference: para. 4, p. 4; para. 6, pp. 4–5

Following an inspection, the Assistant Commissioner reported that both sides claimed rights and that he could not decide the dispute.

Source reference: para. 7, p. 5
02

Issues

Whether the competing claims regarding management of the temple, entitlement to conduct the festival, and the nature of the festival events should be determined by the HR&CE authorities.

Source reference: paras. 7–8, pp. 5–6

Whether the petitioner could be granted permission to conduct the festival before those competing claims were resolved.

Source reference: paras. 7–9, pp. 5–6
03

Law Applied

Section 63 of the Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959, governs the determination of the matters identified by the Court, including claims concerning temple management, the conduct of ceremonies, and traditional rights relating to them.

Source reference: para. 8, p. 6

The Court directed that the Joint Commissioner decide the parties’ claims in accordance with law, on their merits and without reference to caste.

Source reference: para. 8, p. 6

The earlier order had assigned the authorities responsible for law and order that limited role, while directing the HR&CE authority to consider who was entitled to conduct the festival.

Source reference: para. 6, pp. 4–5
04

Reasoning

The Assistant Commissioner’s inspection did not resolve the parties’ competing claims, and the report that both sides asserted rights left the entitlement to conduct the festival undecided.

Source reference: para. 7, p. 5

The Court treated the claims about temple management, festival ceremonies, and any associated traditional rights as matters for determination under Section 63, rather than as questions to be resolved through a law-and-order order.

Source reference: para. 8, p. 6

Because those matters remained pending, the Court directed that the festival be conducted in accordance with the Joint Commissioner’s eventual decision, rather than granting the petitioner immediate permission.

Source reference: para. 8, p. 6
05

Holding

The Court disposed of the writ petition without granting the requested permission to conduct the festival.

It directed that either claimant may apply to the jurisdictional Joint Commissioner, who must give notice to both sides and decide the issues as expeditiously as possible and, in any event, within four months of receiving the application.

Source reference: paras. 8–10, pp. 6–7

The authorities were also directed to inspect the reportedly dilapidated temple and take necessary steps to protect its structure.

Source reference: para. 9, p. 6

No costs were ordered, and the connected miscellaneous petition was closed.

Source reference: para. 10, p. 7
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

TAMIL NADU HINDU RELIGIOUS AND CHARITABLE ENDOWMENTS ACT, 19591

Madras High Court

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THANGAMANI RAJAMANIKKAMvsTHE DISTRICT COLLECTOR

Madras High Court · October 01, 2026

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