Arjun Dass v. State of Andhra Pradesh, 2026

Arjun Dass was recognized as the 21st Mahant (Mathadhipati) of the historic Sri Swamy Hathiramji Mutt, Tirupati.

He had been associated with the Mutt since 1970 and was formally recognized as Mahant in 2000.

His tenure witnessed several disputes with the Andhra Pradesh Endowments Department regarding control over the Mutt's administration and properties.

In 2017, newspaper reports alleged irregularities in the administration of the Mutt.

Based on these allegations, the Andhra Pradesh Dharmika Parishad initiated disciplinary proceedings.

On 8 June 2023, the Parishad framed 16 charges, suspended Arjun Dass from office, and appointed a Fit Person to administer the Mutt.

The charges included allegations of:

• Misappropriation of funds.

• Unauthorized dealings with Mutt properties.

• Acquisition of personal assets.

• Nepotistic appointments.

• Failure to protect Mutt properties.

• Administrative irregularities.

A three-member enquiry committee found all charges proved.

In November 2023, the Parishad removed Arjun Dass from office.

The State Government subsequently confirmed the removal.

The Andhra Pradesh High Court largely upheld the removal order.

Aggrieved, Arjun Dass approached the Supreme Court.

The Supreme Court held that the removal proceedings were fundamentally flawed and violated the principles of natural justice.

The Court found that the charge memo and supporting documents exceeding 600 pages were never properly supplied to the appellant.

It rejected the State's argument that service was effected by affixing notices on the Mutt premises after the authorities themselves had taken possession of those premises.

The Court described the State's stand as a "legal absurdity."

It observed that the enquiry was conducted ex parte, despite repeated requests for documents and adequate opportunity to defend.

The Court held that members of the Dharmika Parishad who initiated proceedings could not subsequently sit in judgment over the same proceedings.

It found that the enquiry violated the rule against bias and the principle that no one should be a judge in his own cause.

The Bench emphasized that the concept of Mahantship integrates both spiritual and administrative functions.

Relying on the Shirur Mutt judgment, the Court held that these functions cannot be permanently separated.

The Court ruled that any arrangement permanently vesting administrative powers in a Fit Person while leaving only spiritual functions to the Mahant would undermine the constitutional concept of Mahantship.

The Court set aside the removal order and the appointment of the Fit Person.

The judgment is a significant reaffirmation of religious autonomy under Article 26.

The Court reinforced the constitutional protection available to religious denominations against excessive State interference.

By relying on Shirur Mutt, the Court reaffirmed the traditional legal understanding of Mahantship as a composite institution involving both spiritual and temporal authority.

The ruling draws an important distinction between regulation and takeover of religious institutions.

While the State may regulate administration to prevent mismanagement, it cannot effectively strip a Mathadhipati of administrative authority while permitting him to retain only ceremonial functions.

The decision strengthens procedural safeguards by insisting upon strict compliance with natural justice before removing religious office-bearers.

The Court's discussion on institutional bias is particularly important because it reiterates that disciplinary bodies must remain independent and impartial.

The judgment serves as a precedent limiting arbitrary governmental control over religious institutions.

By invoking Article 142, the Court ensured a balanced solution that protects both institutional integrity and accountability.