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    <description>Civil courts may entertain disputes over church status, office, worship and administration where civil consequences arise and no ecclesiastical forum exists, and the Places of Worship (Special Provisions) Act, 1991 does not bar suits founded on pre-existing rights. Earlier adjudications were final and binding on the revival of the Catholicate and the validity of the 1934 Constitution. Excommunication of the Catholicos was invalid because it lacked valid canonical basis and failed to conform to the governing Constitution and natural justice. The Malankara Church was held episcopal under the Constitution, with parish churches not autonomous congregational units, while special churches were treated separately according to their own status and constitutional position.</description>
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