Karnataka High Court Sets Aside Government Order Taking Over Anjanadri Mandir, Upholds Puja Rights

The Karnataka High Court has set aside the state government's order regarding the takeover of Anjanadri Mandir, restoring the religious and administrative authority of Vidyadasa Baba to conduct puja and manage temple affairs. The Division Bench's decision, delivered on October 17, 2026, addresses a fundamental procedural defect in how the government initiated enquiry proceedings into alleged temple mismanagement, while simultaneously protecting the custodian's constitutionally guaranteed rights to perform religious rituals.

The case emerged after devotees raised allegations concerning the administration of the temple, the handling of its funds, internal disagreements among those managing its affairs, and uncertainty over the status of the land associated with the institution. These complaints prompted the Commissioner to initiate an enquiry under Section 43(6) of the relevant Act to investigate whether the temple was being mismanaged. However, the manner in which this enquiry was delegated became the crux of the court's intervention.

Procedural Defect in Delegation of Powers

While the Division Bench found that the record contained circumstances capable of supporting the Commissioner's belief that the temple might be mismanaged, it identified a critical procedural violation in how the enquiry was conducted. The Commissioner had empowered the Deputy Commissioner to undertake the enquiry under Section 43(6). Instead of conducting the enquiry himself, the Deputy Commissioner had instructed the Assistant Commissioner to undertake it, which the court held was impermissible.

This constituted an unlawful sub-delegation of statutory enquiry powers. The court recognised that while administrative delegation is sometimes necessary for operational efficiency, the delegation of statutory powers vested in a specific officer must remain within defined legal boundaries. The Deputy Commissioner could not further delegate enquiry powers that were specifically conferred upon him by the Commissioner, as this would amount to an unauthorised transfer of authority beyond what the statute permitted.

The High Court's reasoning reflects established principles of administrative law. When a statute confers powers on a particular officer, that officer bears personal responsibility for exercising those powers. Transferring such powers to a subordinate officer without statutory authorisation undermines the legal framework and denies the affected party the procedural protections built into the statutory scheme. In this case, Vidyadasa Baba was entitled to have his case examined by the officer specifically designated by law to conduct the enquiry.

Restoration of Custodian's Rights

By setting aside the government's takeover order, the High Court restored Vidyadasa Baba's authority to conduct puja and manage temple affairs. This protection recognises that religious rights are not merely personal preferences but are grounded in constitutional protections. The Indian Constitution guarantees citizens the right to freely profess, practise, and propagate religion, subject to public order, morality, and health. Temple custodians and priests occupy a special position within this framework, as their right to conduct religious rituals is integral to the exercise of their own religious freedom and the spiritual life of the community.

The court's decision distinguishes between the state's legitimate interest in investigating potential mismanagement of temple funds and property, and its authority to unilaterally assume control of temple management. While the former serves a valid public purpose, the latter must follow proper legal procedure and cannot override the established rights of a custodian without strict adherence to statutory requirements.

Direction for Fresh Enquiry

Rather than allowing the flawed enquiry to proceed or dismissing the allegations altogether, the Division Bench directed the Deputy Commissioner to conduct the enquiry afresh and submit a report to the Commissioner. This approach balances two competing interests: it protects Vidyadasa Baba's rights by voiding the defective proceedings, while preserving the state's ability to investigate legitimate concerns about temple administration through proper legal channels.

The Deputy Commissioner must now personally conduct the enquiry under Section 43(6) without further sub-delegation. This ensures that the officer vested with statutory authority exercises that authority directly, maintaining the integrity of the investigative process. The fresh enquiry will allow both the state's concerns about potential mismanagement and the custodian's defence of his administrative conduct to be properly examined.

Effect on Temple Administration

The judgment affects how state authorities interact with religious institutions. Many Indian states have legislation governing the management of temples, particularly those with significant endowments or historical importance. These statutes typically vest enquiry and supervisory powers in specific government officers to protect temple funds and ensure proper administration. However, the exercise of these powers must comply with procedural requirements and statutory limits.

The High Court's decision reinforces that administrative convenience cannot justify procedural shortcuts when statutory powers are involved. Government officers cannot simply pass down enquiry responsibilities to subordinates without legal authority to do so. This principle applies across administrative law, not only to temple management but to all areas where statutes confer specific powers on particular officials.

Additionally, the judgment acknowledges that temple custodians and priests have established legal rights that cannot be arbitrarily overridden. While the state retains legitimate oversight functions, these must be exercised through proper legal channels and cannot result in the blanket removal of a custodian's authority without following prescribed procedures. The custodian's right to conduct puja and manage day-to-day temple affairs is protected even during an enquiry into potential mismanagement.