Juristic personality of Guru Granth Sahib upheld, validating religious endowment entries and barring reclamation of dedicated property.

Guru Granth Sahib was recognised as a juristic person because Sikh faith and practice treat it as the living Guru, the spiritual centre of worship, and the legal personality of a religious entity is not limited to idols or any single form of worship. The absence of a separately appointed manager did not defeat that status, and Guru Granth Sahib could hold endowed property. Revenue mutations entered after inquiry into the historical dedication of land for a religious and charitable purpose were therefore upheld, and the endowment was treated as irrevocable. The prior custodians could not reclaim the property once the trust character of the dedication was established.

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Issues: (i) Whether Guru Granth Sahib could be recognised as a juristic person capable of holding property and being the legal centre of a Sikh gurdwara; (ii) whether the revenue mutations and the claim to the disputed property in favour of Guru Granth Sahib and the gurdwara were valid.

Issue (i): Whether Guru Granth Sahib could be recognised as a juristic person capable of holding property and being the legal centre of a Sikh gurdwara

Analysis: The status of juristic personality is a legal recognition extended to an entity other than a natural person where the law attributes rights and duties to it. The Court held that the concept is not confined to idols or any single religious form and may extend to a religious institution or other entity recognised by faith and law. On the evidence of Sikh belief and practice, Guru Granth Sahib is treated as the living Guru, placed at the centre of worship, and revered as the spiritual embodiment of the Sikh faith. The Court held that the absence of idol worship is irrelevant, and that the different religious tradition of Sikhism does not prevent legal recognition of Guru Granth Sahib as a juristic person. The Court also rejected the view that the absence of a separately appointed manager could destroy such personality.

Conclusion: Guru Granth Sahib is a juristic person and can be the legal repository of endowed property.

Issue (ii): Whether the revenue mutations and the claim to the disputed property in favour of Guru Granth Sahib and the gurdwara were valid

Analysis: The Court found that the mutations were not founded merely on the Farman-i-Shahi but were made after enquiry into the historical dedication of the land for a charitable and religious purpose. The property had been entered in the name of Guru Granth Sahib as belonging to the Dharamshala or gurdwara, and the respondents and their predecessors had long stood by without objection. The Court further held that an endowment made for a public religious or charitable purpose is irrevocable and cannot revert to or be reclaimed by the original custodians when they fail to discharge the trust. Once Guru Granth Sahib was held to be a juristic person, the basis on which the High Court had invalidated the mutations disappeared.

Conclusion: The mutations were upheld and the respondents had no enforceable claim to the disputed property.

Final Conclusion: The appeal succeeded and the High Court's decree was set aside, while the Tribunal's orders were restored; the connected special leave petitions were rejected for the same reason.

Ratio Decidendi: A religious entity may be recognised as a juristic person when its faith, worship, and institutional role show that the law must attribute personality to it for the holding and administration of endowed property; an irrevocable religious endowment cannot be reclaimed by those who merely managed it earlier.

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