The Supreme Court has set aside the removal of Sri Swamy Hathiramji Mutt Mathadhipati Arjun Dass, holding that the proceedings initiated by the Andhra Pradesh Dharmika Parishad were vitiated by serious violations of natural justice.
The Court restored his status as Mathadhipati, quashed the removal order and subsequent government confirmation, and ordered a fresh inquiry by an independent retired District Judge-appointed committee instead of remanding the matter to the Dharmika Parishad.
Case Details
- Case Title: Arjun Dass v. State of Andhra Pradesh & Others
- Court: Supreme Court of India
- Bench: Justice J.K. Maheshwari and Justice Atul S. Chandurkar
- Date of Judgment: May 29, 2026
- Citation: 2026 INSC 592
- Case Origin: Civil Appeal arising out of SLP (Civil) No. 38500 of 2025
Background of the Dispute
The litigation concerns Sri Swamy Hathiramji Mutt at Tirupati, one of the most prominent religious institutions associated with the Tirumala-Tirupati region.
Arjun Dass claimed association with the Mutt since 1970, having risen from the position of Pujari to Adhikari, Interim Mahant, and ultimately permanent Mahant.
His appointment as Mathadhipati was recognized by the Akhil Bharatiya Sri Panch Digambar Ani Akhada and formalized through proceedings under the Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, 1987.
The relationship between the appellant and the Endowments Department had been contentious for decades. Previous litigation revolved around control of the secular affairs and properties of the Mutt, with courts directing the authorities to hand over management to Arjun Dass.
The Supreme Court noted that those judicial determinations had attained finality and had even been implemented through government orders.
How the Removal Proceedings Began
The controversy that eventually led to the present appeal gained momentum after allegations surfaced against Arjun Dass regarding the administration of the Mutt.
The Dharmika Parishad, constituted by the State Government in 2022 and consisting entirely of government nominees and ex-officio functionaries, passed a resolution on May 9, 2023 authorizing preparation of charges and suspension proceedings against him.
Following this resolution, the Parishad simultaneously framed 16 charges, suspended him from office, and appointed a “Fit Person” to administer the Mutt. The Endowments Department also took physical possession of the Mutt office and the residence occupied by the Mahant.
The charges ranged from alleged attempts to alienate Mutt property and acquisition of personal properties during his tenure to allegations of financial irregularities, nepotistic appointments, failure to safeguard temple assets, and improper handling of litigation concerning Mutt properties. The inquiry committee eventually found all sixteen charges proved.
Appellant’s Case Before the Supreme Court
The central challenge mounted by Arjun Dass was not merely against the findings on the charges but against the fairness of the entire inquiry process.
According to the appellant, the charge memorandum consisted of 27 pages and was supported by 29 documents exceeding 600 pages. He argued that these materials were never properly supplied to him before the inquiry.
He also contended that despite repeated requests seeking copies of documents and reasonable time to prepare a defence, the inquiry committee proceeded ex parte and concluded the proceedings without affording a meaningful opportunity of hearing.
The appellant further argued that members of the inquiry committee belonged to the very Dharmika Parishad that had already resolved to initiate proceedings against him, thereby violating the principle that no person should be a judge in his own cause.
Supreme Court on Natural Justice
The Supreme Court devoted substantial attention to the doctrine of natural justice and emphasized that removal of a Mathadhipati is not an ordinary administrative action. It affects substantive civil rights, religious office, and spiritual vocation, making procedural fairness indispensable.
Quoting earlier precedent, the Court reiterated:
“No one should be condemned unheard.”
The Bench underscored that an opportunity to defend must be real and effective rather than illusory. A person facing serious charges cannot be expected to answer allegations unless the supporting documents and evidentiary material are first supplied to him.
Examining Section 51(2) of the 1987 Act, the Court held that the statutory requirement of providing an opportunity to “meet the charges” necessarily includes furnishing the allegations, supporting material, and documents relied upon by the authority. Without those materials, meaningful rebuttal becomes impossible.
Service of Documents Found Invalid
One of the most significant findings of the judgment concerns the manner in which the authorities claimed to have served the charge memo.
The respondents argued that the documents were served by affixation on the door of the Mahant’s residence. The Supreme Court rejected this contention after noting that the authorities themselves had already taken possession of the premises before such affixation was carried out.
Photographs and records showed that only six pages relating to the Fit Person’s appointment order had been affixed, while the 27-page charge memo and voluminous supporting documents were never affixed.
The Court described the proposition advanced by the State as a “legal absurdity,” observing that authorities cannot dispossess a person and then claim effective service by pasting notices on the door of premises under their own control.
Requests for Documents Ignored
The Bench also found fault with the inquiry committee’s treatment of the appellant’s repeated communications seeking copies of documents and time to file a defence.
The Court recorded that Arjun Dass, through his advocate, sent multiple communications requesting supply of relied-upon documents and postponement of proceedings until those documents were furnished. Yet the committee ignored those requests and proceeded with the inquiry.
According to the Supreme Court, this conduct amounted to a deliberate disregard of natural justice because it deprived the appellant of any meaningful opportunity to test the evidence against him or lead evidence in his own defence.
Apparent Bias in the Inquiry
The Court also expressed serious reservations about the constitution of the inquiry committee.
Under Rule 26 of the 2009 Rules, the Dharmika Parishad had appointed a three-member committee from among its own members to conduct the inquiry. The Supreme Court observed that such committees were intended primarily for administrative functions and not for quasi-judicial inquiries carrying grave consequences. The Bench warned that allowing members of the adjudicating authority to simultaneously act as investigators and inquiry officers would undermine the very foundations of natural justice.
The Court further noted that the Parishad had already passed a resolution directing preparation of charges and suspension proceedings before the inquiry commenced, creating a reasonable apprehension that the outcome had effectively been predetermined.
Summarizing its conclusions, the Court held that the proceedings were tainted by three major defects:
- Non-supply of the charge memo and relied-upon documents;
- Ignoring requests for documents and conducting an ex parte inquiry;
- A pre-decisional resolution indicating that the process had been predetermined.
Why the Court Refused a Simple Remand
Ordinarily, setting aside such proceedings would have resulted in a remand to the Dharmika Parishad for a fresh inquiry. However, the Supreme Court concluded that the peculiar circumstances of the case required a different approach.
The Court pointed to what it described as structural deficiencies in the statutory framework and concerns arising from the composition of the Dharmika Parishad. It observed that a fresh remand to the same institutional framework could recreate the same concerns regarding fairness and impartiality.
It also highlighted the procedural vacuum regarding how an independent inquiry should be conducted under Section 51(2) of the Act.
Invoking Article 142 of the Constitution, which empowers the Supreme Court to do complete justice, the Bench decided to fashion a one-time case-specific mechanism. Drawing support from earlier constitutional precedents, the Court held that Article 142 could be used to bridge institutional and procedural gaps where ordinary statutory mechanisms were inadequate.
One-Man Inquiry Committee Appointed
The Supreme Court appointed retired District Judge Boddepalli Rama Rao as a one-man independent inquiry committee to conduct a fresh inquiry into all allegations against Arjun Dass.
The Court directed that the inquiry be conducted in accordance with natural justice, including supply of all relevant documents, opportunity to cross-examine witnesses, production of evidence, and submission of a defence.
The State Government and Endowments Department were directed to hand over all materials relied upon in the charge memo within two weeks. The appellant must then receive copies of all documents intended to be relied upon and be granted at least four weeks to submit his defence. The inquiry report is to be completed within one year.
Restoration of Mathadhipati Status
The Court also addressed the position of the Mutt during the pendency of the fresh inquiry.
It restored Arjun Dass to the status of Mathadhipati and permitted him to participate in the religious and spiritual activities of the Mutt. However, recognizing the complexity of the institution’s affairs, the Court simultaneously created an Administrative Committee under Article 142 to assist in governance and ensure transparency.
Decisions of this committee would bind the appellant during the interim period, and he was restrained from alienating Mutt property without its permission.
Supreme Court’s Final Observations
The Court emphasized the unique character of the office of a Mathadhipati, noting that spiritual leadership and administration of Mutt properties are inseparable components of the office.
It held that indefinitely separating a Mahant from the administration of the institution while allowing him to retain only ceremonial religious functions would undermine the very concept of Mahantship recognized in constitutional jurisprudence.
Concluding the matter, the Court stated that Sri Swamy Hathiramji Mutt and its devotees were entitled to a process that was not only fair but also appeared to be fair and unbiased.
Accordingly, it allowed the appeal, set aside the High Court judgment, quashed the removal proceedings, restored the appellant’s status, and directed a fresh inquiry through the independent mechanism created by the Court.
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