Res judicata protects temple administration rights, and indefinite executive takeover cannot override denominational autonomy.

A prior final adjudication recognising the Dikshitars as a religious denomination and confirming their right to administer the temple was binding inter partes and could not be reopened on later legal arguments; the issue was therefore barred by res judicata. The Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959 permitted only limited regulatory control over denominational administration under Article 26 and Section 107, so an Executive Officer could be appointed only within prescribed conditions and for a defined purpose. An indefinite or unconditional takeover could not lawfully supersede denominational management, making the continued executive administration unsustainable.

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Issues: (i) Whether the earlier adjudication recognising the Dikshitars as a religious denomination and affirming their right to administer the temple operated as res judicata and prevented re-examination of the same issue; (ii) whether the appointment and continuation of an Executive Officer under the Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959 could validly displace that right in the absence of prescribed conditions and for an indefinite period.

Issue (i): Whether the earlier adjudication recognising the Dikshitars as a religious denomination and affirming their right to administer the temple operated as res judicata and prevented re-examination of the same issue.

Analysis: The prior judgment had conclusively determined the status of the Dikshitars and their entitlement to administer the temple. That determination attained finality, and the same parties could not reopen the issue by relying on later interpretations of law. The doctrine of res judicata applies with full force to final decisions on questions of status and administration, including in writ proceedings, and even an erroneous decision remains binding inter partes once final.

Conclusion: The issue was barred by res judicata and could not be re-agitated; the earlier recognition of the Dikshitars' right to administer the temple remained binding.

Issue (ii): Whether the appointment and continuation of an Executive Officer under the Tamil Nadu Hindu Religious and Charitable Endowments Act, 1959 could validly displace that right in the absence of prescribed conditions and for an indefinite period.

Analysis: The statutory scheme preserved denominational rights under Article 26 and Section 107, while permitting only regulatory control. The power to appoint an Executive Officer under Section 45 had to operate within prescribed conditions and for a limited purpose tied to correction of maladministration. A takeover of administration cannot amount to permanent supersession, nor can it be sustained where no conditions were prescribed and no duration was fixed. Indefinite displacement of denominational administration was treated as inconsistent with the constitutional and statutory protection of religious autonomy.

Conclusion: The appointment and continued functioning of the Executive Officer, as challenged, were unsustainable.

Final Conclusion: The appeals succeeded because the respondents' administrative rights had already been finally determined and the impugned executive takeover could not legally continue as a permanent or indefinite substitution for denominational management.

Ratio Decidendi: A final adjudication recognising a religious denomination's right to administer its temple binds the parties in subsequent proceedings, and statutory regulatory power cannot be used to effect an indefinite or unconditional supersession of that administration.

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