Case Note & Summary
The Supreme Court of India was approached by way of a writ petition under Article 32 of the Constitution of India by the petitioner, Mrinalini Padhi, seeking directions for an investigation into the disappearance of the keys to the Ratna Bhandar (treasury) of the Shri Jagannath Temple, Puri. The petitioner also prayed for an inventory of the valuables stored in the Ratna Bhandar, the appointment of an expert committee to submit a report for the preservation and management of the temple's property and valuables, and for ensuring express darshan (viewing) for all devotees visiting the temple. The petition relied on the Supreme Court's decision in Sarika v. Administrator, Shri Mahakaleshwar Mandir Committee, Ujjain. Upon entertaining the petition, the Court initially directed the District Judge, Puri, to submit a report on 8 June 2018. Subsequently, on 5 July 2018, the Court issued additional directions, including acceptance of the District Judge's report in principle, requiring the State Government to submit a report from its constituted committee, directing the Central Government to constitute its own committee and place an interim report, and ordering the publication of the District Judge's report on the websites of the temple management, Ministry of Culture, and the Supreme Court. The Court also noted that Hinduism does not eliminate any other belief and directed the temple management to consider permitting every visitor, irrespective of faith, to offer respects and make offerings, subject to regulatory measures. The Court appointed Senior Counsel Shri Ranjit Kumar as Amicus Curiae and requested Senior Counsel Ms. Priya Hingorani to assist him. The Amicus Curiae submitted interim reports. During the pendency of the petition, the State Government of Odisha decided to acquire land for providing facilities to pilgrims, including a watch tower, evacuation plan, and road widening, which was gazetted on 27 August 2019. The Court heard the parties and expressed satisfaction with the State Government's action. The District Judge's report included various annexures, such as sketch maps, CCTV camera details, lists of cases against sevaks (servitors), vacancy positions, fund management details, audit reports from the Accountant General, Odisha, extracts from the Record of Rights under the Puri Shri Jagannath Temple (Administration) Act, 1952, and reports from various committees and commissions of inquiry. The audit report covered aspects like fund management, estate management, project management, financial management, utilization of grants-in-aid, unrealistic budgeting, inflated utilization certificates, contract management, human resource management, and observations on jewellery and ornament maintenance. The Court also considered the report of the committee headed by Shri B.D. Sharma, which recommended accommodation for 60,000 pilgrims, improvements in sevapuja (rituals), appointment of sevaks, and other facilities. The Court noted that the learned counsel expressed satisfaction with the State Government's actions pursuant to the resolution dated 27 August 2019. The Court did not pass any further orders at that stage, effectively allowing the ongoing process to continue.
Headnote
A) Constitutional Law - Public Interest Litigation - Article 32 of the Constitution of India - Maintainability - Petition filed under Article 32 seeking investigation into disappearance of keys to Ratna Bhandar of Shri Jagannath Temple, Puri, inventory of valuables, appointment of expert committee, and express darshan for devotees - Court entertained the petition and issued directions for reports from District Judge, State Government, and Central Government (Paras 1-2). B) Temple Administration - Management and Preservation - Puri Shri Jagannath Temple (Administration) Act, 1952 and Shri Jagannath Temple Act, 1954 - Court accepted report of District Judge, Puri, and directed compliance by temple administration - State Government's resolution dated 27.8.2019 for land acquisition and pilgrim facilities noted with satisfaction - Amicus Curiae appointed to submit reports and engage with stakeholders (Paras 2-4). C) Audit and Financial Management - Fund and Estate Management - Accountant General, Odisha audit report - Observations on fund management, estate management, project management, financial management, utilization of grants-in-aid, unrealistic budget, inflated utilization certificates, contract management, human resource management, and non-maintenance of asset registers - Court considered audit report as part of proceedings (Paras 6-7). D) Pilgrim Facilities - Accommodation and Darshan - Recommendations of B.D. Sharma Committee - Provision of accommodation for 60,000 pilgrims, queue system, and express darshan - Court directed consideration of dress code and permitting visitors irrespective of faith to offer respects (Paras 2, 7).
Issue of Consideration
Whether the Court should direct an investigation into the disappearance of keys to the Ratna Bhandar of Shri Jagannath Temple, Puri, order an inventory of valuables, appoint an expert committee for preservation and management, and ensure express darshan for devotees.
Final Decision
The Court accepted the report of the District Judge, Puri in principle and directed compliance by temple administration. The Court noted the State Government's resolution dated 27.8.2019 for land acquisition and pilgrim facilities with satisfaction. The Court appointed Shri Ranjit Kumar as Amicus Curiae and Ms. Priya Hingorani to assist. The Court directed the Central Government to constitute a committee and submit an interim report. The Court also directed the District Judge to send further reports and the State Government to submit its committee's report. The Court permitted the temple management to consider dress code and permitting visitors irrespective of faith. The Court directed every District Judge in India to examine similar matters and send reports to the concerned High Court. The Court did not pass any further orders at this stage, effectively allowing the ongoing process to continue.
Law Points
- Article 32 of the Constitution of India
- Puri Shri Jagannath Temple (Administration) Act
- 1952
- Shri Jagannath Temple Act
- 1954
- Public Interest Litigation
- Temple Management
- Pilgrim Facilities
- Audit and Fund Management



