Customary succession to Mahantship upheld while an unsupported lease was held not binding on the religious endowment.

In a religious endowment governed by custom, succession to Mahantship had to be proved by the institution's established usage. The alleged successor failed to prove a valid chela relationship with the deceased Mahant, while the appellant was shown by oral and contemporaneous evidence to be a Bhatija chela and a spiritual collateral validly appointed by the Bhek and the Sewaks. The lease executed by the deceased Mahant was not shown to be supported by legal necessity: the premium was found fictitious, the rent was grossly inadequate, and no prudent management justification was proved. The appellant's title to Mahantship was upheld and the challenged lease was held not binding on the institution.

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Issues: (i) whether the deceased Mahant left any chela and whether the respondent claimed and proved succession to Mahantship through a valid chela relationship; (ii) whether the appellant was a spiritual collateral eligible under the custom of the institution and was validly appointed by the Bhek and the Sewaks; (iii) whether the lease executed by the deceased Mahant was supported by legal necessity and binding on the institution.

Issue (i): whether the deceased Mahant left any chela and whether the respondent claimed and proved succession to Mahantship through a valid chela relationship.

Analysis: Succession to Mahantship depended on the proved custom of the institution. The evidence, including revenue records, conduct, and surrounding circumstances, did not establish that the alleged successor was a chela of the deceased Mahant. The alleged earlier will was not proved, and the later will did not appoint him as Mahant but only as a joint manager, with little evidentiary value in the circumstances.

Conclusion: It was not proved that the respondent was a chela of the deceased Mahant or otherwise entitled to succeed on that basis, and the finding was against the respondent.

Issue (ii): whether the appellant was a spiritual collateral eligible under the custom of the institution and was validly appointed by the Bhek and the Sewaks.

Analysis: The proved custom was that succession lay through appointment by the Bhek and the Sewaks, but the appointee had to be chosen from the deceased Mahant's disciples, or failing them, from his spiritual kindred. The oral evidence and the earlier judgment relied upon were sufficient to show that the appellant was a Bhatija chela and thus a spiritual collateral. The contemporaneous record of the meeting showed that the Bhek and the Sewaks assembled and appointed him, and the objections to the meeting were not borne out by the evidence.

Conclusion: The appellant was eligible for appointment and was validly appointed Mahant by the Bhek and the Sewaks, and this issue was decided in his favour.

Issue (iii): whether the lease executed by the deceased Mahant was supported by legal necessity and binding on the institution.

Analysis: The burden lay on the lessees to show that the transaction was a prudent act of management. The alleged premium was found to be fictitious, the rent was grossly inadequate, and no evidence was led to justify the bargain or prove necessity. On these facts the lease could not be upheld as binding on the endowment.

Conclusion: The lease was not binding on the institution and this issue was decided against the lessees.

Final Conclusion: The appellant established his title to Mahantship and succeeded in invalidating the challenged lease, so the decree of the trial court was restored and the appeal succeeded.

Ratio Decidendi: In a religious endowment governed by custom, succession to Mahantship must be proved by the established usage of the institution, and an alienation by a Mahant will bind the endowment only if the transferee proves that it was a bona fide and necessary act of management.

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