Real and substantial interest is required for standing in a public religious trust suit; mere possible worship is insufficient.

A representative suit concerning a public religious trust under Section 92 CPC requires the plaintiff to show a real and substantial interest in the trust. Mere membership of the Sikh community was held insufficient because the plaintiffs did not prove they were actual worshippers of the Gurdwara or that they had any personal connection with the institution. The material also treated the institution as associated with Nirmala Sadhus, whose identity and practices were distinct from the general body of Sikhs, and a bare possibility of resorting to the place of worship was found inadequate to establish standing.

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Issues: Whether the plaintiffs had locus standi to maintain the suit under Section 92 of the Code of Civil Procedure as persons having a real interest in the religious trust.

Analysis: The suit could be maintained only by persons having a real and substantial interest in the trust. The plaintiffs failed to prove that they were actual worshippers of the Gurdwara, and mere membership of the Sikh community did not by itself establish the requisite interest. The evidence also showed that the institution was associated with Nirmala Sadhus, whose practices and identity were treated as distinct from the general body of Sikhs, and the plaintiffs did not establish any personal connection with the institution sufficient to satisfy the statutory requirement. A bare or speculative possibility of resorting to the place of worship was held insufficient to confer the necessary standing.

Conclusion: The plaintiffs had no locus standi to sue under Section 92 of the Code of Civil Procedure, and the appeal succeeded.

Ratio Decidendi: To maintain a representative suit in respect of a public religious trust, the plaintiff must show a real and substantive interest in the trust, and a mere remote or possible right of worship is not enough.

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