Church governance and res judicata bar parallel management; appointment of vicars remains a secular administrative function.

The SC affirmed that the 1934 Constitution of the Malankara Church validly governs parish churches, their internal administration, and church property, and that contrary Udampady arrangements and the later 2002 Constitution could not displace that settled framework. It further held that issues already finally decided in earlier representative litigation, including the validity of the 1934 Constitution and limits on rival control, were barred by res judicata and constructive res judicata. The appointment of vicars and other office-holders was treated as a secular administrative function, not a basis for parallel management under Articles 25 and 26. No court-framed scheme under Section 92 CPC or interim divided arrangement was warranted.

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Issues: (i) whether the 1934 Constitution of the Malankara Church governs the parish churches and prevails over contrary Udampady arrangements and the later 2002 Constitution; (ii) whether the binding effect of the earlier representative litigation and principles of res judicata preclude re-agitation of the same questions; (iii) whether the appointment of vicars, priests and other office-holders can be claimed as a matter of spiritual supremacy under Articles 25 and 26 of the Constitution of India; and (iv) whether a scheme under Section 92 of the Code of Civil Procedure, 1908 or an interim parallel arrangement was warranted.

Issue (i): whether the 1934 Constitution of the Malankara Church governs the parish churches and prevails over contrary Udampady arrangements and the later 2002 Constitution.

Analysis: The Constitution of 1934 was held to have been validly adopted and to regulate the internal administration of the Malankara Church, including parish assemblies, managing committees, diocesan control, appointment and transfer of vicars, and supervision of church property. The earlier Udampady instruments were treated as arrangements for administration, not as documents creating an overriding title to displace the constitutional scheme, and inconsistent provisions were held to stand annulled. The later 2002 Constitution could not displace the binding constitutional framework or justify a parallel system of church management.

Conclusion: The 1934 Constitution governs the parish churches and prevails over the Udampady arrangements and the 2002 Constitution.

Issue (ii): whether the binding effect of the earlier representative litigation and principles of res judicata preclude re-agitation of the same questions.

Analysis: The earlier disputes were litigated in representative proceedings concerning the common rights and properties of the Malankara Church. Findings on the validity of the 1934 Constitution, the limits of patriarchal power, the status of the Catholicate, and the inability of rival factions to reclassify themselves by adopting a new constitution had already been finally decided. By virtue of the representative character of the earlier suits and the doctrine of res judicata, including constructive res judicata, those issues could not be reopened by parish-level litigation or by reframing the same controversy through new pleadings.

Conclusion: Re-agitation of the concluded issues was barred by res judicata and the earlier representative decrees bind the parties and those interested in the trust.

Issue (iii): whether the appointment of vicars, priests and other office-holders can be claimed as a matter of spiritual supremacy under Articles 25 and 26 of the Constitution of India.

Analysis: The Court drew a distinction between religious belief and the secular or managerial incidents of church administration. While members may hold faith in patriarchal spiritual supremacy, the appointment of vicars and similar office-holders was held to be an administrative function governed by the constitutional scheme of the church and not an essential religious practice that could be used to create a competing administrative structure. Articles 25 and 26 do not permit a faction to override a settled ecclesiastical-administrative arrangement or to take over church management under the guise of religion.

Conclusion: Appointment of vicars and related office-holders is a secular administrative matter governed by the 1934 Constitution and not a basis for parallel control under Articles 25 and 26.

Issue (iv): whether a scheme under Section 92 of the Code of Civil Procedure, 1908 or an interim parallel arrangement was warranted.

Analysis: The 1934 Constitution itself provided a detailed and workable scheme for the governance of the church and its properties, leaving no necessity for court-framed management directions. An interim arrangement dividing religious services between rival factions would amount to legitimising parallel administration and was inconsistent with the settled constitutional structure. The reliefs sought for a new scheme and for divided management were therefore rejected.

Conclusion: No scheme under Section 92 was required and no interim parallel arrangement could be sanctioned.

Final Conclusion: The appeals failed because the settled constitutional regime of the Malankara Church remained binding, the earlier representative decisions operated as res judicata, and the rival claim to independent or parallel management could not be sustained.

Ratio Decidendi: In a representative dispute concerning a religious trust, an earlier final determination on the governing constitution and the limits of managerial authority binds all interested persons, and a faction cannot invoke freedom of religion to displace a settled administrative scheme by creating a parallel system of control.

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