Secular regulation of temple administration upheld, including replacement of hereditary trusteeship and reform of traditional emoluments.

The statutory scheme governing Hindu charitable and religious institutions treats administration and management as secular regulation, while leaving faith, worship and essential religious practices untouched. Hereditary trusteeship was treated as a matter of succession in office rather than an essential religious practice, so the legislature could replace it with a board-based appointment system under Sections 15 and 16. Sections 17 and 29(5) were also sustained as administrative safeguards, including regard to the founder's wishes and family representation where possible, with the Executive Officer's role confined to supervision. Section 144, abolishing traditional shares and emoluments, was upheld as a reform measure aimed at preserving institutional resources. The scheme was found consistent with Articles 14, 15(1), 25 and 26.

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Issues: (i) whether the abolition of hereditary trusteeship and the statutory scheme for appointment of trustees under Sections 15 and 16 of the Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, 1987 is constitutionally valid; (ii) whether Sections 17 and 29(5), which regulate the composition of the board and the role of the Executive Officer, are valid; (iii) whether Section 144 abolishing traditional shares and emoluments is unconstitutional; and (iv) whether the impugned provisions offend Articles 14, 15(1), 25 and 26 of the Constitution of India.

Issue (i): whether the abolition of hereditary trusteeship and the statutory scheme for appointment of trustees under Sections 15 and 16 of the Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, 1987 is constitutionally valid.

Analysis: The statutory scheme treats administration and management of religious and charitable institutions as secular regulation, while leaving untouched matters of faith, worship, tenets and essential religious practices. The right to establish and maintain such institutions is recognised, but the right of management may be regulated by law. Hereditary trusteeship was held to be a matter of succession in office and not an indispensable part of religion. The legislature was entitled to remove hereditary preference as a facet of secular reform and to provide collective management through a board of trustees. The classification of Hindu institutions for such regulation was not found unconstitutional merely because similar measures had not yet been extended to all religions in one sweep.

Conclusion: Sections 15 and 16 are constitutionally valid and the challenge to abolition of hereditary trusteeship fails.

Issue (ii): whether Sections 17 and 29(5), which regulate the composition of the board and the role of the Executive Officer, are valid.

Analysis: The requirement that the appointing authority have regard to the wishes of the founder and the institution's denomination, together with the provision that one trustee should, if qualified, be from the founder's family, was treated as a significant safeguard. The provisions were read as part of a scheme intended to secure proper and efficient administration rather than to displace the founder's influence altogether. The Executive Officer's powers were viewed as administrative and supervisory, designed to ensure lawful and efficient management, and not as an invasion of religious freedom. Subject to the interpretive safeguard that the board should ordinarily be headed by the founder or a family member, the provisions were sustained.

Conclusion: Sections 17 and 29(5) are valid, subject to the construction that the board should be headed by the founder or a member of the founder's family where possible.

Issue (iii): whether Section 144 abolishing traditional shares and emoluments is unconstitutional.

Analysis: The abolition of shares in offerings and related emoluments was treated as a legislative measure aimed at preventing misuse of institutional funds and ensuring that the resources of the institution remain dedicated to the charitable or religious purpose. The Court deferred to the legislative judgment on the need for such reform and found no want of legislative competence. The provision was upheld as a valid measure of secular administration and reform.

Conclusion: Section 144 is not unconstitutional.

Issue (iv): whether the impugned provisions offend Articles 14, 15(1), 25 and 26 of the Constitution of India.

Analysis: The Court held that Article 25(2) permits laws regulating secular activities associated with religion, and Article 26 protects administration of property only in accordance with law. Hereditary preference was viewed as a ground of discrimination inconsistent with Article 15(1), while the regulatory scheme was held not to violate Article 14 because the State may proceed in stages to remedy perceived mischief in a particular class of institutions. The impugned law was thus treated as a permissible regulatory and reformist measure rather than an intrusion into essential religious matters.

Conclusion: The impugned provisions do not violate Articles 14, 15(1), 25 or 26 of the Constitution of India.

Final Conclusion: The statutory scheme regulating the administration of Hindu charitable and religious institutions was upheld, with a limited interpretive safeguard in relation to the leadership of the board under Sections 17 and 29(5); the challenge to the constitutionality of Sections 15, 16, 17, 29(5) and 144 therefore fails.

Ratio Decidendi: Administration of religious and charitable institutions is a secular activity that may be regulated by law, and hereditary trusteeship is not an essential religious practice protected from reform; a statute may validly replace hereditary management with a regulated board structure so long as matters of faith and worship remain untouched.

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