Temple property dedication may be inferred from conduct, and worshippers can challenge unauthorized alienation by a manager.

Dedication of private property to a religious endowment may be proved orally or inferred from conduct, and an admission in prior litigation treating the shop as temple property could bind a successor-in-interest unless satisfactorily explained. The earlier finding was therefore required to be reconsidered on remand. In a public temple, worshippers are beneficiaries and have standing to challenge an unauthorized alienation of immovable temple property by the manager, so the suit for declaration that the sale deed was void was maintainable. The judgment was set aside and the question of dedication was sent back for fresh consideration.

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Issues: (i) Whether the shop was dedicated to the deity and whether the earlier admission made in the prior suit could be relied upon against the successor-in-interest to infer such dedication. (ii) Whether worshippers of a public temple could challenge the alienation of temple property by the manager.

Issue (i): Whether the shop was dedicated to the deity and whether the earlier admission made in the prior suit could be relied upon against the successor-in-interest to infer such dedication.

Analysis: Dedication of private property for a religious purpose need not be in writing and may be made orally or inferred from conduct. The prior suit instituted by Ram Babu treated the disputed shop as temple property and described him as manager of the temple. The admission in that proceeding was relevant conduct and could bind his successor-in-interest unless explained. The earlier courts had proceeded on an erroneous assumption regarding the status of Ram Babu in that litigation and had not examined whether the admission stood explained or whether it supported an inference of dedication.

Conclusion: The issue required reconsideration by the High Court, and the finding against the appellants could not be sustained as final.

Issue (ii): Whether worshippers of a public temple could challenge the alienation of temple property by the manager.

Analysis: In a public religious endowment, the beneficiaries are the worshippers, and they are entitled to challenge an alienation of immovable property made by the manager. The suit sought a declaration that the sale deed was void because the seller had no authority to alienate property belonging to the temple. Such a suit was maintainable.

Conclusion: The suit by the worshippers was maintainable and the challenge to its maintainability failed.

Final Conclusion: The judgment under appeal was set aside and the matter was remitted for fresh consideration on the question of dedication, while the connected review petition became infructuous and the challenge to the maintainability of the suit failed.

Ratio Decidendi: Dedication to a religious endowment may be proved by conduct and admissions in prior proceedings may bind a successor-in-interest unless satisfactorily explained; worshippers of a public temple have standing to challenge an unauthorized alienation of temple property.

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