Writ jurisdiction cannot be invoked to bypass statutory remedies by suppressing material facts and prior knowledge.

The petitioner, claiming to be a shebait of Jamwai Mata Temple, challenged an order dated 30.04.2010 passed by the Assistant Commissioner, Devasthan.

The 2010 order, passed under Section 23 of the Rajasthan Public Trust Act, 1959, accepted "Form 8" changes regarding trustees and immovable properties of respondent No. 1 Trust.

The petitioner appealed this order in 2019 (Appeal No. 13/2019) before the Commissioner, Devasthan (Appellate Authority), which was dismissed on 21.04.2022 due to an inordinate delay of 10 years.

The petitioner then invoked Article 226 of the Constitution, alleging that the 2010 proceedings were void ab initio for lack of notice to interested persons.

Respondents countered that the petitioner suppressed material facts, including prior knowledge of the Trust via letters signed in 2017 and the existence of a parallel civil suit filed by family members.

Whether the Appellate Authority erred in dismissing the appeal on the grounds of limitation given the alleged lack of knowledge of the 2010 order.

Whether the writ petition is maintainable despite the concealment of material facts and the availability of an alternative statutory remedy.

Rajasthan Public Trust Act, 1959, specifically Section 23 regarding inquiries into changes of entries, Section 20 regarding appeals, and Section 22, which mandates that any person aggrieved by an entry must institute a civil suit for cancellation or modification.

Dalip Singh v. State of U.P. (2010) and K.D. Sharma v. SAIL (2008), which hold that a litigant who suppresses material facts or bases a case on falsehoods is not entitled to extraordinary relief.

The Court found the Appellate Authority’s dismissal on limitation to be well-reasoned and rejected the petitioner’s claim of "sudden discovery" of the 2010 order in 2019, noting that correspondence from 2017 (to which the petitioner was a signatory) irrefutably established prior knowledge.

The Court emphasized that the petitioner approached the Writ Court with "unclean hands" by suppressing these 2017 letters and the fact that a parallel suit (No. 7/2018) had already been filed by other shebaits for identical relief.

Furthermore, since the entries had already been amended in the register, Section 23(4) read with Section 22 of the Act provides a specific, efficacious statutory remedy via a civil suit.

The Court determined it was inappropriate to resolve complex, contested historical facts regarding temple properties and shebait rights in a writ jurisdiction when a statutory civil remedy exists.

The Court found the appeal was rightly dismissed as time-barred due to the 10-year delay and the petitioner's dishonest narrative regarding his knowledge of the proceedings.

The petitioner’s conduct in suppressing the 2017 letters and the parallel civil litigation disentitled him to equitable relief.

The petitioner is at liberty to pursue the alternative statutory remedy under Section 22 of the Act, but the present petition was dismissed without costs.