The Supreme Court ruled that the Special Synod Meeting of the Church of South India (CSI) on 07.03.2022 was validly convened, but amendments to the CSI Constitution increasing clergy retirement age were invalid due to insufficient ratification by diocesan councils. The Moderator’s election was declared invalid, while other office bearers’ elections were upheld pending final suit disposal.
Facts Of The Case:
The dispute arose from the election of office bearers in the Church of South India (CSI), an unregistered religious body. The plaintiffs challenged amendments to the CSI Constitution, particularly the increase in retirement age for clergy from 67 to 70 years, alleging procedural irregularities. They also contested the election of the Moderator, citing criminal antecedents. Four civil suits were filed before the Madras High Court, seeking interim reliefs, including the appointment of an administrator and fresh elections.
The High Court initially restrained the implementation of the amendments and later declared the electoral college flawed, ordering fresh elections. The Supreme Court examined the validity of the Synod meeting, the ratification process of amendments, and the elections. It found that while the meeting was duly convened, the amendments lacked proper ratification. The Moderator’s election was invalid due to non-compliance with retirement age rules, but other office bearers’ elections were upheld subject to the final outcome of the suits.
Procedural History:
The case originated from four civil suits filed before the Madras High Court, challenging the amendments to the CSI Constitution and the election of office bearers. The Single Judge granted interim relief, restraining the implementation of amendments and directing fresh elections for the Moderator. The Division Bench upheld parts of the Single Judge’s order but declared the entire electoral college flawed, appointing a Committee of Administrators. The Supreme Court, in appeal, partially set aside the Division Bench’s order, restoring the Single Judge’s findings on the validity of the Synod meeting and the elections of other office bearers.
Court Observation:
The Supreme Court observed that the Special Synod Meeting was validly convened, but the constitutional amendments lacked proper ratification by two-thirds of diocesan councils, rendering them unenforceable. The Moderator’s election was invalid due to non-compliance with retirement age rules. However, the elections of other office bearers were upheld as the alleged irregularities in the electoral college did not materially affect the outcome. The Court emphasized that interim relief should not pre-judge the final merits of the suits.
Final Decision & Judgement:
The Supreme Court quashed the Division Bench’s order, restoring the Single Judge’s findings. It upheld the invalidity of the amendments and the Moderator’s election but sustained the elections of other office bearers, subject to the final suit outcome. The Court directed that the interim injunction against implementing the amendments would continue until the suits’ disposal.
Case Details:
Case Title: Dr. Vimal Sukumar vs. D. Lawrence & Ors. Citation: 2025 INSC 622 Civil Appeal No.: Arising out of SLP (C) Nos. 9079-9081 of 2024 Date of Judgment: May 02, 2025 Judges: Justice Bela M. Trivedi & Justice Satish Chandra Sharma
Download The Judgement Here