Special statute for temple management prevails; public interest litigation cannot bypass statutory remedies or justify a roving inquiry.

A special statute governing temple administration provided a complete machinery for supervision, audit, removal of erring functionaries, supersession of the committee and related remedies, so public interest litigation should not ordinarily be used to bypass that framework. The Court emphasised judicial restraint where the legislature has created dedicated forums and procedures, particularly in matters affecting temple management and religious practices. It also noted that the High Court had gone beyond permissible review by appointing a commissioner, seizing records and conducting a roving inquiry in a manner closer to a commission of inquiry, without first allowing the statutory authorities to act. The adverse observations against the appellant were expunged, while residual issues were left for the State to decide under the Act.

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Issues: Whether a public interest petition could be entertained in relation to the management of a temple governed by a special statute, and whether the High Court could bypass the statutory machinery by appointing a commissioner, seizing records, and issuing wide-ranging directions in the nature of an inquiry.

Analysis: The statutory scheme governing the temple provided a complete code for administration, supervision, audit, removal of erring functionaries, supersession of the committee, call for records by the Government, and rule-making power. The Court reiterated that public interest litigation is meant to advance access to justice for the disadvantaged and not to supplant statutory procedures or enter areas reserved to the executive or statutory authorities. It held that where the legislature has created forums and remedies, those remedies should ordinarily be pursued first, and the Court should exercise self-restraint, especially in matters implicating temple management, religious practices, and the competing sentiments of devotees. The Court further held that the High Court had adopted an unusual course by conducting a roving inquiry through a commissioner and other assistance, a course more akin to a commission of inquiry, without showing adequate necessity or first allowing the statutory authorities to act. However, the Court also noted that the High Court had uncovered several irregularities and that many of its directions had already been implemented by the State.

Conclusion: The public interest litigation was not a proper vehicle to bypass the statutory framework, and the High Court exceeded the proper limits of judicial review in several respects; nevertheless, the proceedings were not set aside in toto, and the appeals succeeded only to the extent that the adverse remarks against the appellant were expunged and the remaining matters were left to the State to decide in accordance with law.

Final Conclusion: The statutory regime governing the temple remained paramount, public interest jurisdiction could not be used to displace it, and the impugned adverse observations were removed while the State was left to deal with any residual issues under the Act.

Ratio Decidendi: Where a special statute provides a self-contained machinery for administration and redress, the Court should not ordinarily bypass that machinery through public interest litigation or assume the role of the statutory authority by conducting a roving inquiry or issuing directions that effectively supplant the statute.

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