The Supreme Court ruled on the ownership dispute between ISKCON Bangalore (registered under Karnataka Societies Act) and ISKCON Mumbai (Maharashtra Public Trust) over temple properties. It upheld the Trial Court’s decree declaring ISKCON Bangalore as the rightful owner, citing documentary evidence (sale deeds, allotment records) and rejecting claims of fraudulent manipulation. The Court dissolved the oversight committee, emphasizing societies’ independent legal status under state registration laws. The judgment clarified that funding sources (even from ISKCON Mumbai) don’t determine ownership, and dismissed ancillary appeals linked to the dispute.
Facts Of The Case:
The case involved a protracted legal battle between ISKCON Bangalore (registered under the Karnataka Societies Registration Act, 1960) and ISKCON Mumbai (a Maharashtra-registered trust) over ownership and management of temple properties in Bangalore. The dispute originated from conflicting claims about which entity legally owned the land and assets of the ISKCON temple in Bangalore, acquired in the 1980s. ISKCON Bangalore filed Suit No. 7934 of 2001, asserting absolute ownership based on a 1988 sale deed from the Bangalore Development Authority (BDA), which explicitly allotted the land to it. ISKCON Mumbai countered, claiming the property belonged to its Bangalore branch, alleging fraudulent use of its funds and documents by ISKCON Bangalore’s office-bearers, including Madhu Pandit Dasa. Parallel litigation (Suit No. 1758 of 2003) addressed governance disputes within ISKCON Bangalore, where plaintiffs sought declarations about the legitimacy of its managing committee. The Trial Court ruled in favor of ISKCON Bangalore in 2009, but the High Court reversed this in 2011, siding with ISKCON Mumbai. The Supreme Court, however, reinstated the Trial Court’s decree, emphasizing BDA records and sale deeds as conclusive proof of ISKCON Bangalore’s ownership. It dismissed allegations of fraud, noting ISKCON Mumbai’s failure to substantiate claims, and dissolved the oversight committee appointed earlier to manage the temple. The judgment ended a 20+ year legal battle, affirming the primacy of documentary evidence in property disputes.
Procedural History:
The procedural history of this case spans over two decades of litigation across multiple judicial forums. The dispute originated with Suit No. 7934 of 2001 filed by ISKCON Bangalore before the City Civil Court, Bangalore, seeking declaration of ownership over temple properties and injunctions against ISKCON Mumbai’s interference. The Trial Court decreed in favor of ISKCON Bangalore in 2009, recognizing its ownership based on the 1988 BDA sale deed. Concurrently, Suit No. 1758 of 2003 addressed internal governance disputes within ISKCON Bangalore, which was dismissed by the Trial Court and affirmed by the Karnataka High Court in RFA No. 423 of 2009. ISKCON Mumbai challenged the 2009 decree in RFA No. 421 of 2009, where the High Court reversed the Trial Court’s decision in 2011, declaring ISKCON Mumbai as the rightful owner through its Bangalore branch. The Supreme Court intervened in 2014, appointing an oversight committee (headed by retired Justice R.V. Raveendran) to manage the temple pending resolution. Appeals against the High Court’s 2011 judgment (Civil Appeal Nos. 9313–9316/2014) and the governance dispute (Civil Appeal Nos. 3821–3822/2023) were consolidated. In its 2025 judgment, the Supreme Court set aside the High Court’s 2011 ruling, restored the Trial Court’s 2009 decree, and dissolved the oversight committee, concluding the 24-year legal battle. The Court emphasized the sanctity of documentary evidence (BDA records) and dismissed ISKCON Mumbai’s fraud allegations as unsubstantiated.
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Court Observation:
The Supreme Court made several critical observations in its judgment. It emphasized that documentary evidence, particularly the BDA sale deed (1988) and allotment records, conclusively established ISKCON Bangalore’s ownership of the disputed properties. The Court rejected ISKCON Mumbai’s claims of fraudulent manipulation, noting the absence of credible evidence to prove that the Bangalore branch acted as its proxy. It underscored that registration under state laws (Karnataka Societies Act) granted ISKCON Bangalore independent legal status, irrespective of funding sources or administrative overlaps with ISKCON Mumbai.
The Court criticized the prolonged litigation (spanning 24 years) as contrary to the spirit of the ISKCON movement, observing that such disputes tarnished the organization’s spiritual mission. It highlighted the failure of ISKCON Mumbai to:
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Register the property under the Maharashtra Public Trusts Act,
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Correct BDA records post-allotment, and
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Substantiate its fraud allegations with contemporaneous documents.
The Bench also noted the irrelevance of funding sources to determine ownership, clarifying that even if ISKCON Mumbai contributed financially, it did not ipso facto transfer title. It dissolved the oversight committee, stressing that judicial intervention in religious administration should be temporary and exceptional. The judgment reaffirmed the principle that civil courts must prioritize documentary evidence over speculative claims in property disputes.
Final Decision & Judgement:
The Supreme Court delivered a decisive judgment, allowing Civil Appeal No. 9313/2014 and dismissing Civil Appeal Nos. 3821-3822/2023, thereby settling the decades-long dispute. It restored the Trial Court’s 2009 decree, declaring ISKCON Bangalore as the lawful owner of the temple properties based on irrefutable documentary evidence, including the BDA sale deed (1988) and allotment records. The Court set aside the Karnataka High Court’s 2011 reversal, holding that ISKCON Mumbai failed to prove its claims of fraudulent manipulation or establish legal ownership through its Bangalore branch.
Key directives included:
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Dissolution of the oversight committee (headed by Justice R.V. Raveendran) within one month, ending interim judicial management.
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Dismissal of all ancillary appeals (Civil Appeal Nos. 9305-9316/2014) as infructuous.
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Reaffirmation of ISKCON Bangalore’s independent legal status under the Karnataka Societies Registration Act, irrespective of funding sources or administrative ties to ISKCON Mumbai.
The Court imposed no costs, urging both parties to prioritize the ISKCON movement’s spiritual objectives over litigation. The judgment underscored the sanctity of documentary evidence in property disputes and barred further claims over the disputed properties, bringing finality to the 24-year legal battle.
Case Details:
Case Title:Prasannatma Das vs. K.N. Haridasan Nambiar (Dead) & Others Citation:(2025) INSC 717 Civil Appeal Nos.: Civil Appeal Nos. 3821-3822 of 2023 (Arising from Suit No. 1758/2003)With Connected Matter Date of Judgment:May 16, 2025 Bench:Justice Abhay S. Oka & Justice Augustine George Masih
Download The Judgement Here