Supreme Court Dismisses Appeal in the Dispute Over Trust Property of Kamakala Kameshwarar Temple

Supreme Court Dismisses Appeal in the Dispute Over Trust Property of Kamakala Kameshwarar Temple

On September 13, 2024, the Supreme Court of India dismissed the civil appeal in Civil Appeal No. 8374 of 2024, involving the dispute over the ownership and title of a trust property related to the Kamakala Kameshwarar Temple. The appeal, filed by Sri Siddaraja Manicka Prabhu Temple, challenged the judgment passed by the Madras High Court on October 26, 2017, which had upheld the decision that the disputed property was trust property and not under the absolute ownership of the appellant.

Background of the Case

The case revolves around the ownership of an immovable property adjacent to the Kamakala Kameshwarar Temple (referred to as the "suit property"). This property, along with the temple, was originally owned by Rai Raja Eswardoss Diawanth Bahadur, whose son and grandson, T. Lakshmidoss and T. Venkataprasad, were declared insolvents by the Madras High Court in 1914. As part of the insolvency proceedings, the properties, including the suit property, were placed under the control of the Official Assignee.

In 1917, Mr. W. Ramakrishna Lala purchased the suit property and established a trust to manage it. The trust deed allowed the income generated from the property to be used for the benefit of the insolvent family and the maintenance of the Kamakala Kameshwarar Temple and the Guru Manicka Prabhu Temple. However, after multiple insolvency declarations and subsequent legal proceedings, the property’s title and ownership became a matter of dispute between the appellant and the respondent.

Madras High Court Ruling

The Madras High Court, in its 2017 judgment, ruled in favor of the respondent, the Kamakala Kameshwarar Temple, declaring the suit property as trust property. The High Court held that the appellant, who initially sought hereditary trusteeship, could not claim absolute ownership over the suit property. The court pointed out that the compromise decree of 1929, which established the trust, required the income from the property to be used for the maintenance of the temples. The appellant had allegedly misused the property’s income for personal gain, forfeiting their position as trustee.

Supreme Court's Judgment

In the appeal before the Supreme Court, the appellant argued that the property was their private property and that no trust deed was executed to designate it as trust property. The appellant claimed that the Conveyance Deed of 1931 identified them as the absolute owner of the property, not merely as a trustee. They further contended that the suit filed by the respondent did not comply with Section 92 of the Code of Civil Procedure, 1908, which pertains to suits related to trusts.

The Supreme Court, after considering the submissions and reviewing the documents, upheld the decision of the Madras High Court. The Court ruled that the suit property is part of the trust and the appellant holds it in trustee capacity, not as the absolute owner. The court observed that the property had been explicitly vested in the trust for the upkeep and maintenance of the temples. The compromise decree of 1929 and the Conveyance Deed of 1931 clearly indicated that the property was meant for the benefit of the temples, and the appellant’s failure to properly manage the property’s income led to the forfeiture of their position as trustee.

Key Points from the Judgment:

1. The compromise decree of 1929 explicitly vests the suit property in the trust for the maintenance of the temples.

2. The appellant was merely a trustee of the property, not the absolute owner.

3. The Supreme Court rejected the argument that the proceedings were barred by res judicata, as the earlier litigation dealt with a separate issue—the public or private status of the Kamakala Kameshwarar Temple.

4. The Supreme Court found that the appellant’s claim of absolute ownership was unsupported by the evidence, and the terms of the trust deed were upheld.

Conclusion

The Supreme Court dismissed the appeal and reaffirmed the Madras High Court’s ruling that the Kamakala Kameshwarar Temple is a public trust and the suit property continues to be part of that trust. This decision reinforces the legal obligations of trustees to manage trust properties in accordance with the terms of the trust and for the benefit of the beneficiaries.