Madras High Court Directs Revenue Records to Reflect Temple Deity's Name Alone
The Madurai Bench of the Madras High Court has ruled that temple properties must be recorded in the name of the presiding deity alone, rather than in the name of a hereditary trustee representing the deity. The Court held that recording temple property in the trustee's representative capacity would violate the legal principle laid down by the Supreme Court.
The ruling was delivered by Justice K. Kumaresh Babu on November 3, 2026, in The Executive Officer, Arulmighu Mutharamman Thirukovil v. The Commissioner of Land Administration & Ors. (W.P.(MD) No. 25244 of 2026).
Background of the Case
The dispute arose from proceedings dated July 22, 2026, issued by the Commissioner of Land Administration, directing mutation of revenue records in the name of Sree Narguna Sundara Vinayakar Temple, represented by its hereditary trustee.
The Executive Officer of Arulmighu Mutharamman Thirukovil challenged the order under Article 226 of the Constitution of India, seeking correction of the revenue records and issuance of patta in the name of the temple deity.
Supreme Court Precedent on Temple Property
The High Court relied upon the Supreme Court's ruling in Civil Appeal No. 4850 of 2021, which clarified that the name of the deity alone should be entered in revenue records, rather than that of the temple manager or priest.
The Supreme Court had recognised a limited exception permitting the names of Poojaris who perform religious functions and cultivate the land to be mentioned in the remarks column.
The High Court observed that the absence of executive instructions from the Tamil Nadu Revenue Department could not justify non-compliance with the law declared by the Supreme Court.
Court Rejects Hereditary Trustee's Representation
The Court held that recording the deity's name as being represented by its hereditary trustee was contrary to the Supreme Court's legal position. It also rejected the objection concerning the maintainability of the petition, observing that a deity is treated as a minor in law and that the Court could exercise its parens patriae jurisdiction to protect its interests.
Final Directions
The High Court directed that the revenue records must reflect the name of Sree Narguna Sundara Vinayagar Balasubramaniar alone. It further held that the land classification as "Natham Private" was not recognised under the applicable Revenue Standing Order and directed that it be classified as "Natham" in the deity's name.
Additionally, the Court directed the Secretary, Revenue and Disaster Management Department, Tamil Nadu, to issue necessary executive instructions and ensure that revenue authorities make the required corrections in accordance with paragraph 27 of the Supreme Court's judgment.
Legal Significance
The decision reinforces the legal distinction between ownership of temple property and its administration. Hereditary trustees, managers and priests may perform management or religious functions, but their positions do not justify recording temple property in their personal or representative names in revenue records contrary to the governing Supreme Court ruling.
The judgment strengthens the protection of religious endowment property and emphasises that binding Supreme Court principles must be followed by revenue authorities even in the absence of subsequent executive instructions.