Composite religious property title turned on evidence of possession and use, while partition beyond pleadings was rejected and relief was restructured.

Title to a composite disputed religious site was examined through evidence of dedication, waqf by user, adverse possession, and lost grant, and the Muslim claim failed for lack of reliable proof and deficient pleadings. The Hindu parties were found to have a better possessory claim on the evidence of continuous worship, historical record, and site materials, while the faith-based claim that the central dome area was the birthplace of Lord Ram was accepted. A three-way partition was rejected as beyond the pleadings, and final relief was moulded through constitutional powers, including vesting the site in a trust for temple construction and allotting alternative land for a mosque.

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Issues: (i) Whether the Sunni Central Waqf Board established title to the disputed site by dedication, waqf by user, adverse possession, or lost grant; (ii) whether the Hindus established possessory title to the disputed site and the disputed structure as the birthplace of Lord Ram; (iii) whether the High Court could direct a three-way partition of the disputed property; and (iv) what relief should follow on the title and possession findings.

Issue (i): Whether the Sunni Central Waqf Board established title to the disputed site by dedication, waqf by user, adverse possession, or lost grant.

Analysis: The claim of an express dedication was not proved by reliable evidence. The plea of waqf by user failed because the evidence did not establish long, uninterrupted, exclusive Muslim use of the entire composite site from antiquity, and the outer courtyard had been used and possessed by Hindus for worship. The alternative plea of adverse possession also failed because the pleadings were deficient and the evidence did not show peaceful, open, continuous and hostile possession of the whole property. The doctrine of lost grant was inapplicable because it was neither properly pleaded nor supported by evidence, and it cannot be used to override the competing and established rights shown by the record.

Conclusion: The Sunni Central Waqf Board did not establish title by dedication, waqf by user, adverse possession, or lost grant.

Issue (ii): Whether the Hindus established possessory title to the disputed site and the disputed structure as the birthplace of Lord Ram.

Analysis: The evidence, including travelogues, gazetteers, oral testimony, site plans, and the surrounding historical record, showed continuous Hindu worship at the outer courtyard and a long-standing faith that the sanctum beneath the central dome was the birthplace of Lord Ram. The setting up of the railing in 1856-57 was treated as a peace measure and not a determination of title. The record also showed that Hindu worship continued openly at Ramchabutra, Sita Rasoi, and related structures, while the inner courtyard remained contested. On the balance of probabilities, the Hindus established a better possessory claim to the composite site than the Muslim parties.

Conclusion: The Hindus established a better possessory title to the disputed site, including the outer courtyard, and the faith-based claim that the central dome area was the birthplace of Lord Ram was accepted.

Issue (iii): Whether the High Court could direct a three-way partition of the disputed property.

Analysis: The High Court was not deciding a suit for partition, and the relief granted went beyond the pleadings and the prayers in the suits. A civil court cannot recast the frame of litigation and grant a partition-style division where that was not sought or supported by the pleadings. The earlier findings that two suits were time-barred did not justify allotting shares to those parties. The partition decree was therefore legally unsustainable.

Conclusion: The three-way partition directed by the High Court could not be sustained.

Issue (iv): What relief should follow on the title and possession findings.

Analysis: The Court held that Suit 3 was barred by limitation, Suit 4 was within limitation, and Suit 5 was within limitation and maintainable. The relief was moulded under constitutional powers to secure justice and restore the consequences of unlawful dispossession. The disputed site was directed to be handed over for construction and management of a temple through a trust or body to be constituted by the Central Government, while the Sunni Central Waqf Board was to be allotted five acres of land in Ayodhya for a mosque and associated facilities. The right of worship of the first plaintiff in Suit 1 was affirmed subject to lawful restrictions.

Conclusion: Suit 3 was dismissed, Suit 4 was partly decreed with allotment of alternative land, and Suit 5 was decreed with directions for vesting the disputed property in a trust or body to be constituted by the Central Government.

Final Conclusion: The competing religious claims were resolved by holding that the Hindu claim to the disputed site had the better evidentiary foundation, while the Muslim parties were granted restitutive relief in the form of alternative land and the matter was finally disposed of with consequential directions for implementation through a statutory scheme.

Ratio Decidendi: Title to a composite disputed property must be determined on evidence of possession, use, and legal entitlement, and not on faith alone; claims of waqf by user, adverse possession, or lost grant require strict proof, while a court cannot grant partition-like relief beyond the pleadings.

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