The Supreme Court has ended a nearly five‑decade legal battle over the “Moorti Swarup Shri Govardhan Nath Ji” temple in Rampura Bazar, Kota, by holding that management of a religious institution cannot be treated as proof of ownership over its property.
The court allowed the appeal of the legal heirs of Kishan Chand, the former pujari‑cum‑custodian, and set aside the 1988 trial court and 2007 Rajasthan High Court decrees that had ordered him to hand over possession to a local society.
The bench of Justices Vikram Nath and Sandeep Mehta reiterated that the law draws a clear distinction between supervising a temple and holding legal title to its land, idols, ornaments, shops, and agricultural holdings. The court observed that administrative control, appointment of pujaris, and the practice of seva‑puja are functions of temple management, not markers of proprietary rights.
The Supreme Court found a “fundamental infirmity” in the reasoning of the Kota trial court and the Rajasthan High Court, which had focused on the weakness of Kishan Chand’s hereditary‑claim case, instead of independently testing the plaintiffs’ title.
The court stressed that a plaintiff in a title suit must prove ownership with positive evidence; a plaintiff “cannot succeed on the weakness of the defendant’s case.” The society failed to produce any deed of dedication, endowment record, or other admissible document showing that the temple property stood vested in it.
By dismissing the civil suit of Gautam Gaur Hitkarak Sabha, the Supreme Court has created a strong precedent: merely running a temple, appointing pujaris, and collecting temple‑shop income do not convert a religious body into the legal owner of the property.
The judgment reinforces that in any dispute over ancient Hindu shrines, the burden lies squarely on the party claiming ownership to substantiate that claim with documentary and legal proof, not on ritual or managerial control.
