Special Honours at Temple Cannot Be Claimed as Absolute Right

Source: Madras High Court 

Why in News? 

The bench of Justice SM Subramaniam and Justice C Kumarappan in the case of Srirangam Srimath Andavan Ashramam v. Thathadesikar Thiruvamsathar Sabha & Ors. (2025) held that special honours in a temple cannot be claimed as an absolute right and that the first honour in the temple was always to the deity, while dismissing the appeal of an ashramam seeking first special honour for its head at the Sri Devaraja Swamy Temple in Kanchipuram. 

What was the Background of Srirangam Srimath Andavan Ashramam v. Thathadesikar Thiruvamsathar Sabha & Ors. (2025) Case? 

• The original writ petition was filed by Thathadesikar Thiruvamsathar Sabha seeking to prevent the HR & CE authorities from interfering with the religious usage and customs of the Sri Devaraja Swamy Temple. 
• In the writ petition, the single judge held that honour could be extended only to 5 mutts as per practice, namely: Kanchi Kamakoti Peetam - Sankara Mutt, Kanchipuram; Sri Ahobila Mutt; Sri Vanamalai Mutt, Nangunery; Sri Parakala Jeeyar Mutt, Mysore; and Sri Vyasarayar Mutt, Sosale (Udupi). 
• The single judge ruled that if honour was extended to anyone else, it would be open to challenge. 
• The present appeal was filed by Srirangam Srimath Andavan Ashramam as a third party challenging the order. 
• The appellant argued that the practice of honouring the appellant mutt head had been dispensed with unfairly. 
• The appellant contended that they had not been made a party to the writ petition and could not defend their case. 
• The appellant claimed that its head had been conferred honour at the temple on five occasions after 1991. 
• The HR & CE Department submitted that as per the customs and usage, honours were being conferred on only 5 mutts traditionally. 

What were the Court's Observations? 

• The Court emphasized that special honours in temples cannot be demanded as an absolute right, stating that such honours, though followed as practice, must be evaluated by competent authorities. 
• The bench clarified that "the 1st honour is always to the deities in the Temple and honouring Heads of Mutts, though being followed as a practice, is an issue to be decided by the competent authority under the Act." 
• The Court acknowledged that the HR&CE Department did not dispute that honour had been conferred on the head of appellant mutt on five occasions after 1991. 
• The Court noted that whether such honour could be claimed as a right or not was to be determined by the competent authority under the Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959, specifically under Section 63(e) of the said Act. 
• The Court gave liberty to the petitioner to approach the competent authority under Section 63(e) of the Act for determination of their claim. 
• Finding no infirmity with the single judge's order, the Court was not inclined to entertain the appeal and dismissed the same. 

What is the Legal Framework for Temple Administration in India? 

About: 

• The Tamil Nadu Hindu Religious and Charitable Endowments (HR&CE) Act, 1959 governs the administration and management of Hindu temples and religious institutions in Tamil Nadu. 
• The Act provides for the proper administration, maintenance and management of Hindu religious and charitable institutions and endowments. 
• Section 63(e) of the HR&CE Act specifically deals with the powers of the competent authority to decide disputes relating to customs and usage in temples. 
• The HR&CE Department is the statutory body responsible for overseeing temple administration, including matters related to religious customs and practices. 

Temple Honours and Customs: 

• Temple honours are privileges extended to religious leaders, mutt heads, or other distinguished persons as part of temple traditions and customs. 
• Such honours have historically been conferred based on established practices, religious significance, and the relationship between mutts and temples. 
• The practice of honouring mutt heads reflects the interconnection between various Hindu religious institutions and their respective traditions. 
• Customs and usage in temples are typically determined by historical practice, religious texts, and established conventions followed over time. 

Distinction Between Practice and Right: 

• While certain practices may be followed traditionally in temples, they do not automatically translate into enforceable legal rights. 
• The determination of whether a practice constitutes a right requires examination by competent authorities under the relevant statutory framework. 
• The first and paramount honour in any temple is always to the deity, not to any individual or institution. 
• Religious practices and honours must be evaluated within the framework of temple administration laws and constitutional principles of equality and non-discrimination.