The Supreme Court appointed a retired High Court Judge as the Administrative Head/Administrator to oversee elections and administer the affairs of the Oachira Parabrahma Temple in Kerala. The judgment addresses disputes over the temple's administration and directs elections under the temple's bye-laws within four months.

The case revolves around the dispute regarding the administration of the Oachira Parabrahma Temple and its allied institutions. The Supreme Court directed the conduct of fresh elections under the supervision of an appointed Administrative Head to resolve the conflict and ensure proper governance until the final framing of a scheme by the trial court.

Para-wise Main Facts with Headings:

1. Introduction and Appeal:

   • The appellants, elected representatives of the Oachira Parabrahma Temple, challenged orders passed by the Kerala High Court, which included appointing an Administrative Head and removing the elected committee.

2. Temple History and Governance:

   • The temple, unique for lacking a sanctum sanctorum and idols, is managed under bye-laws by three elected committees: General Board, Working Committee, and Executive Committee. The appellants held office from 2017, but no elections were conducted thereafter.

3. Suit for Scheme Framing (2006):

   • A 2006 suit sought to frame a scheme for temple administration. A 2010 trial court judgment allowed the existing bye-laws to govern until the scheme was finalized.

4. High Court Directions:

   • The High Court appointed an Administrative Head to supervise temple affairs and draft a scheme but removed the elected Executive Committee.

5. Contentions Before the Supreme Court:

   • The appellants argued that the High Court exceeded its jurisdiction by removing the elected committee and appointing unelected administrators contrary to the bye-laws.

6. Supreme Court Observations:

   • The Court emphasized the temple's unique status and the need for orderly governance. It acknowledged disputes between the elected committee and the High Court-appointed Administrative Head.

7. Election Oversight Directions:

   • The Supreme Court appointed Hon'ble Justice K. Ramakrishnan (Retd.) as the new Administrative Head to conduct elections within four months, in adherence to the bye-laws.

8. Implementation and Accountability:

   • Existing arrangements would continue until elections are held. The Administrative Head was directed to report back to the Supreme Court upon completion of the election process.

9. Trial Court Mandate:

   • The trial court was instructed to expedite the final decree proceedings for framing the scheme.

Acts and Sections Discussed:

1. Constitution of India: Articles related to the jurisdiction and powers of the Supreme Court and High Courts.

2. Civil Procedure Code: Provisions on appeals, framing of schemes, and interlocutory applications.

Ratio Decidendi:

1. The Supreme Court underscored that disputes concerning religious institutions must be resolved with utmost care to preserve heritage and public interest.

2. Appointing an independent Administrative Head and conducting elections under existing bye-laws ensures transparency and upholds democratic principles.

3. The High Court cannot act beyond its jurisdiction post-final judgment.

Subjects:

Governance of Religious Institutions; Administrative Law; Election Oversight.

• Religious Institutions

• Temple Administration

• Election Oversight

• High Court Jurisdiction

• Supreme Court Judgment

• Kerala Temples

• Scheme Framing

• Administrative Dispute

• Transparency and Accountability.