Public trust only construction under the Bihar Hindu Religious Trust Act defeated interference with a private religious trust.

The Supreme Court of India construed the Bihar Hindu Religious Trust Act, 1950 as confined to public religious trusts, reading the definition clause with the Act's scheme on supervision, cy-pres application, scheme settlement, trustee removal, and its link to earlier public-endowment legislation. Although the definition of "religious trust" was broad in form, it was not extended to private religious trusts. On that construction, the constitutional challenge under Article 19(1)(f) did not require final determination. The writ appeal succeeded, the High Court's judgment was set aside, and the demand for accounts and interference with management was quashed unless the trust was duly determined to be a public trust.

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Issues: Whether the Bihar Hindu Religious Trust Act, 1950 applied to private religious trusts, and if so whether its restrictions offended the fundamental right to property under Article 19(1)(f) of the Constitution of India.

Analysis: The definition of "religious trust" in section 2(1), read with section 4(5) and the other operative provisions, was construed in the context of prior legislation dealing only with public religious and charitable endowments. The Court held that the scheme of the Act, including provisions concerning supervision, cy-pres application of trust property, settlement of schemes on applications by interested persons, removal of trustees, and exclusion of earlier public-trust enactments, indicated that the Act was directed only at public trusts. The definition clause, though wide in form, was not intended to include private religious trusts. In view of that construction, the constitutional challenge under Article 19(1)(f) did not require final determination.

Conclusion: The Act did not apply to private religious trusts, and the appellant was entitled to relief.

Final Conclusion: The writ appeal succeeded, the High Court's judgment was set aside, and the Board's demand for accounts and interference with management was quashed unless and until the trust was duly determined to be a public trust.

Ratio Decidendi: Where a statute governing Hindu religious trusts, read as a whole and in light of earlier enactments, discloses a scheme confined to public trusts, it cannot be extended to private religious trusts merely because the definition clause is broadly worded.

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