Temple Festival Committee | Inclusive Representation Mandated Under Article 226 : Madras High Court

The Madras High Court has reaffirmed the constitutional mandate of inclusive governance in religious affairs by directing the formation of a representative committee for temple festival celebrations. This judgment underscores that religious administration cannot be monopolized by any single community when multiple groups are stakeholders, reinforcing Article 226 as a tool for equitable dispute resolution in matters of public worship.

Background & Facts

The Dispute

The petitioner, a resident of Melapanankadi village in Madurai district, sought judicial intervention to ensure the fair conduct of the Kumbabishegam festival scheduled for 08.02.2026 at four local temples: Arulmighu Ayyanar Temple, Arulmighu Muniyandi Swamy Temple, Arulmighu Karupasamy Temple, and Arulmighu Muthumariamman Temple. The dispute arose when the fifth respondent, also a village resident, claimed exclusive rights to conduct the festival, despite the presence of five distinct communities in the village.

Procedural History

The case emerged in the context of an ongoing legal battle over temple administration:

• W.P.(MD).No.168 of 2026: A prior writ petition filed by one Sevugamoorthy, where the Court directed the Hindu Religious and Charitable Endowments (HR&CE) Department to appoint a fit person for temple management.
• 29.01.2026: The HR&CE Department complied with the order, appointing a fit person.
• 25.08.2026 and 28.01.2026: The petitioner submitted representations to the authorities, seeking the formation of a community-based committee to oversee the festival.

Relief Sought

The petitioner invoked Article 226 of the Constitution to seek a Writ of Mandamus, directing the third and fourth respondents (the Tahsildar and Inspector of Police) to:

1. Form a committee comprising representatives from the Mutharayar, Maravar, and Adhi Dravidar communities.
2. Ensure the committee, in collaboration with the fit person, conducts the festival without discrimination.

The Legal Issue

The Court was tasked with resolving two critical questions:

1. Whether Article 226 empowers the High Court to intervene in disputes over the administration of religious festivals when multiple communities claim rights.
2. Whether the principle of inclusive representation must prevail over individual claims to exclusive control in matters of public worship.

The Court's Analysis

The Court grounded its reasoning in constitutional principles of equality and non-discrimination, emphasizing that religious administration must reflect the pluralistic composition of the community. Key observations included:

1. Judicial Oversight in Religious Affairs: The Court noted that while religious freedom is guaranteed under Article 25, the state’s regulatory power under Article 26 extends to ensuring that religious institutions are managed in a manner that upholds public order, morality, and health. The appointment of a fit person by the HR&CE Department was cited as a legitimate exercise of this regulatory authority.

2. Inclusive Governance as a Constitutional Mandate: The judgment highlighted that when multiple communities coexist in a village, no single group can claim exclusive rights to conduct religious festivals. The Court observed:

"The Kumbabishekam cannot be conducted by an individual, especially when there are five communities in the village and the order has already been passed for the appointment of a Fit Person. Hence, it would be appropriate to form a committee including the said villagers."

1. Prohibition of Discrimination: The Court explicitly prohibited the conferral of "First Honour" on any individual or community, reinforcing that religious ceremonies must be conducted on an egalitarian basis. This direction aligns with the constitutional prohibition of untouchability under Article 17 and the right to equality under Article 14.

2. Role of the Fit Person: The Court clarified that the fit person, appointed by the HR&CE Department, must act as a neutral facilitator rather than an arbiter of community disputes. The fit person was directed to form a committee with one representative from each community, ensuring that all stakeholders have a voice in the festival’s administration.

The Verdict

The Court allowed the writ petition and issued the following directions:

1. The fit person is directed to appoint one representative from each of the five communities in Melapanankadi village to form a committee.
2. The committee, in collaboration with the fit person, shall conduct the Kumbabishegam festival scheduled for 08.02.2026.
3. No individual or community shall be accorded "First Honour" or any preferential treatment during the festival.
4. The fifth respondent is directed to hand over all relevant records to the committee and the fit person.

The writ petition was disposed of with no order as to costs.

What This Means For Similar Cases

Inclusive Representation Is Non-Negotiable

The judgment establishes a clear precedent that in matters of public worship, exclusive control by a single community cannot be permitted when multiple groups are stakeholders. Practitioners should note:

• Article 226 can be invoked to ensure equitable participation in religious affairs, particularly when disputes arise over festival administration.
• Courts are likely to favor committee-based governance over individual claims, especially in villages with diverse communities.

Fit Persons Must Act as Neutral Facilitators

The role of the fit person, appointed under the HR&CE Act, is clarified as that of a neutral coordinator rather than a decision-maker. Key takeaways include:

• Fit persons cannot unilaterally decide which community conducts a festival.
• Their mandate includes forming inclusive committees and ensuring compliance with court directions.

Discrimination in Religious Ceremonies Is Justiciable

The Court’s prohibition of "First Honour" underscores that even symbolic discrimination in religious ceremonies can be challenged under Article 226. Practitioners should:

• Argue that preferential treatment in temple festivals violates Articles 14, 15, and 17 of the Constitution.
• Highlight the public character of religious institutions to justify judicial intervention in disputes over their administration.

Procedural Compliance Is Critical

The judgment reinforces that prior court orders (such as the appointment of a fit person) must be strictly adhered to in subsequent proceedings. Non-compliance may lead to:

• Contempt proceedings against erring authorities.
• Directions for inclusive governance as a corrective measure.