Supreme Court Restores Trial Court Decree on Bangalore ISKCON Property, Sets Aside High Court Finding of Mumbai Society’s Title

A bench of Justices Abhay S. Oka and Augustine George Masih heard a clutch of appeals arising from long‑running disputes between ISKCON Mumbai and ISKCON Bangalore concerning title to land and control of the Bangalore temple and societies; the appeals arose out of Suit Nos. 7934 of 2001 and 1758 of 2003 and connected Regular First Appeals decided by the Karnataka High Court.

The Court allowed Civil Appeal No. 9313 of 2014, set aside the High Court judgment in RFA No. 421 of 2009 and restored the Trial Court decree in Suit No. 7934 of 2001 declaring ISKCON Bangalore to be the owner of the Schedule ‘A’ property. The Court dismissed Civil Appeal Nos. 3821‑3822 of 2023 which challenged the Trial Court and High Court findings on the composition of the Governing Body in Suit No. 1758 of 2003. The Court directed that the committee headed by Justice R.V. Raveendran (retd.) overseeing the temple management would stand dissolved one month from the date of the judgment and recorded that there would be no orders as to costs. The Court emphasised that the dispositive conclusion turned on documentary evidence of allotment and conveyance to the registered Karnataka society. The Court, in its reasoning, observed: "Therefore, for the reasons recorded above, the High Court's finding that ISKCON Mumbai, through its branch in Bangalore, was the owner of the schedule A property is completely erroneous and deserves to be set aside. It is completely contrary to the documentary evidence. Even assuming that ISKCON Bangalore did not possess funds, and even if money came from ISKCON Mumbai, it cannot claim ownership. Only because the existence of the Bangalore branch of ISKCON Mumbai was proved, one cannot jump to the conclusion that allotment of Schedule ‘A’ property was to ISKCON Mumbai through the Bangalore branch." The Court also observed that "it is crystal clear that Schedule ‘A’ property was allotted by the BDA to ISKCON Bangalore, and ISKCON Bangalore is an independent society registered under the Karnataka Societies Registration Act."

Background The disputes arose from competing claims to property (Schedule ‘A’: 6 acres 8 guntas at Rajajinagar Extension, Bangalore) and to control of the Bangalore society. ISKCON Bangalore, a society registered under the Karnataka Societies Registration Act (1978), contended that the Bangalore Development Authority (BDA) allotted and the BDA executed a registered sale deed dated 3 August 1988 in its favour. ISKCON Mumbai, also a registered entity (and a public trust under the Maharashtra Public Trusts Act), contended that the land and temple had been acquired for ISKCON Mumbai through its Bangalore branch under the supervision of Madhu Pandit Dasa and that donations mobilised using ISKCON Mumbai’s exemption certificates financed acquisition and construction.

At trial the City Civil Court accepted ISKCON Bangalore’s title and granted declarations and injunctions. The Karnataka High Court in RFA No. 421 of 2009 allowed the appeal, concluded that the Bangalore temple and properties were owned by ISKCON Mumbai through its Bangalore branch, and recorded findings of manipulations and branch operation. This Court examined the documentary trail — notably the application for allotment dated 5 February 1987 (Exh.P‑51), correspondence, deposit challans, the registered sale deed dated 3 August 1988 and exemption under the Urban Land Ceiling Act — and found that the record uniformly named ISKCON Bangalore as the applicant and allottee. The Court found no contemporaneous application by ISKCON Mumbai or its branch and held that the High Court’s conclusion that the allotment was to ISKCON Mumbai was contrary to the documentary evidence. The Court further noted concurrent findings on the 1 July 1984 general body meeting in Suit No.1758 of 2003 and declined to disturb the Trial Court and High Court conclusions in that suit, dismissing the appeals in Civil Appeal Nos.3821‑3822 of 2023. The Court recorded its view that the long litigation ought to be brought to a close and indicated unwillingness to proceed on the contempt petition and related FIR matters.

Case Details: Case No.: 2025 INSC 717 Case Title: Prasannatma Das v. K.N. Haridasan Nambiar & Others Appearances: For the Petitioner(s): Counsel not specified in the published judgment For the Respondent(s): Counsel not specified in the published judgment