Substantial compliance in pleadings governs hereditary office-holder claims where succession facts are clearly set out.

Substantial compliance with pleadings is sufficient where a petition under the Sikh Gurdwaras Act clearly sets out the line of succession and the substance of the claim to hereditary office. A rigid insistence on express pleading of the precise custom of succession is unwarranted when the pleaded facts and evidence show devolution by hereditary right or nomination by the existing office-holder and no prejudice is demonstrated. The Tribunal's acceptance of a Guru-to-Chela succession was therefore supportable on the material, and the petition was not incompetent for want of sufficient pleadings; the petitioner was entitled to be treated as a hereditary office-holder.

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Issues: Whether the petition under Section 8 of the Sikh Gurdwaras Act was incompetent for want of sufficient pleadings to establish the petitioner as a hereditary office-holder.

Analysis: The statutory definition of hereditary office-holder turns on devolution according to hereditary right or nomination by the existing office-holder. The High Court applied a rigid standard and treated the absence of an express pleading of the precise custom of succession as fatal. The Tribunal, however, had accepted the pleaded line of succession from Guru to Chela and, on the evidence, had found that the office devolved according to hereditary right. The correct approach was one of substantial compliance, not technical insistence on formulaic pleadings, especially where the substance of the claim and the course of succession were made clear and no prejudice was shown.

Conclusion: The petition was not incompetent on the ground of pleadings, and the petitioner was entitled to be treated as a hereditary office-holder.

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