Consent decree interpretation allows surrounding conduct and pleadings to clarify temple worship and offering rights

A consent decree may be read as a contract with court seal, but it can also operate as an estoppel and be construed with the pleadings, surrounding circumstances and subsequent conduct where its language is ambiguous or incomplete. On that approach, the reference to offerings made to a poojari in his individual capacity had to be understood in light of temple custom, separate ceremonial acts and the parties' later acknowledgments of equal worship rights. The evidence was not barred by Section 92 of the Indian Evidence Act in these circumstances. The decree therefore did not exclude the plaintiffs' claim to the disputed worship and offering rights.

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Issues: Whether the compromise decree governing the hereditary turn of worship had to be construed strictly on its text alone, or along with the pleadings, surrounding circumstances and subsequent conduct, and whether the respondents could claim exclusive rights over offerings said to be made in the poojari's individual capacity.

Analysis: A consent decree is a contract with the seal of the Court, but it may also operate as an estoppel. In construing such a decree, the Court may look to the pleadings and the proceedings leading to it, especially where the language is not fully exhaustive or is ambiguous. The record showed that the parties' rights of worship were not in dispute, and that the expression referring to offerings made to the first defendant in his individual capacity had to be understood in the context of the temple customs and the nature of separate ceremonies performed by a priest. The Court also relied on the contemporaneous conduct of the parties, including later documents in which the plaintiffs' branch was acknowledged as having equal rights in worship and offerings. In these circumstances, Section 92 of the Indian Evidence Act was held not to bar such evidence.

Conclusion: The compromise decree did not exclude the plaintiffs' claim to the disputed rights in the manner held by the High Court, and the respondents could not deny the plaintiffs' entitlement on that basis.

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