Public trust disputes must go to the statutory forum where the Act provides a complete mechanism for property, succession and management issues.

The Rajasthan Public Trust Act, 1959 provides a self-contained mechanism for registration of a public trust, inquiry into trust property, determination of succession, correction of entries, management, audit and appeals. On that scheme, disputes over the nature of trust property, succession to the office of Mahant and related management issues were matters for the statutory authorities, including the Assistant Commissioner, who had competence to inquire into them. The Supreme Court therefore approved the High Court's decision to relegate the parties to the statutory forum rather than decide those controversies in public interest jurisdiction. The Court also declined interference with the treatment of a separate writ petition as infructuous and with any direction for continued committee management.

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Issues: (i) Whether the High Court was justified in relegating the parties to the Assistant Commissioner without deciding the merits of the disputes concerning the nature of the trust property and succession to the office of Mahant; (ii) Whether the Assistant Commissioner had jurisdiction under the Rajasthan Public Trust Act, 1959 to decide those disputes; (iii) Whether the appellant could challenge the order treating the separate writ petition as infructuous and seek a direction for continued management by a committee.

Issue (i): Whether the High Court was justified in relegating the parties to the Assistant Commissioner without deciding the merits of the disputes concerning the nature of the trust property and succession to the office of Mahant.

Analysis: The Act created a complete statutory mechanism for registration of a public trust, inquiry into trust property, determination of succession, correction of entries, further inquiry, management, audit, and appeals. The dispute involved long-standing questions of title, succession, and management, all of which were already the subject of pending proceedings under the Act. In those circumstances, the High Court was justified in declining to decide the controversies in a public interest proceeding and in directing the parties to pursue the statutory forum.

Conclusion: The issue was answered against the appellant and in favour of relegation to the statutory authority.

Issue (ii): Whether the Assistant Commissioner had jurisdiction under the Rajasthan Public Trust Act, 1959 to decide those disputes.

Analysis: Sections 17, 18, 19, 20, 21, 22, 23, 24, 38, 39, 40, 41, 43, 49, 52, 53, 54, 55, 56 and 67 of the Act showed that the Assistant Commissioner and Commissioner were vested with broad inquiry powers, including powers analogous to a civil court in specified matters. The Act specifically empowered inquiry into whether property belonged to the trust, the mode of succession, management issues, and further inquiries after registration. On that scheme, the Assistant Commissioner was competent to examine the disputes raised in the writ petitions.

Conclusion: The issue was answered in the affirmative and against the appellant.

Issue (iii): Whether the appellant could challenge the order treating the separate writ petition as infructuous and seek a direction for continued management by a committee.

Analysis: The writ petition had been filed by another party, who withdrew it after the term of the committee had expired. The appellant was not a party to that writ petition and did not object at the relevant stage. Further, the statutory scheme made appointment of a committee dependent on governmental satisfaction, and the dispute had already moved into the statutory appellate process. In these circumstances, no interference was warranted with the High Court's treatment of that writ petition or with the absence of a direction to constitute a fresh committee.

Conclusion: The issue was answered against the appellant.

Final Conclusion: The statutory framework provided an effective and adequate forum for resolution of the trust-property and succession disputes, and the High Court rightly declined to entertain the controversy in public interest jurisdiction. The appeals were therefore not fit for interference.

Ratio Decidendi: Where a special statute provides a self-contained mechanism and vested authorities to decide disputed questions concerning public trust property, succession, and management, the High Court should ordinarily relegate the parties to that statutory forum rather than adjudicate the dispute in public interest litigation.

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