Summary
The Supreme Court set aside the Kerala High Court’s ruling that parishioners could control appointments and management of St Mary’s Church, Kattachira, independently of the Malankara hierarchy. Binding earlier judgments, the 1934 Church Constitution and the gift deed placed the church under the Metropolitan’s authority. A parallel administration could not be justified by the Patriarch’s spiritual supremacy, and the asserted religious-rights objection did not require a fresh Constitution Bench reference.
Issues
- Whether parishioners could independently appoint clergy and manage the Kattachira church despite the 1934 Constitution and gift deed.
- Whether the asserted Articles 25 and 26 objection required a five-judge reference.
Provisions considered
- Articles 25 and 26, Constitution of IndiaThe Court endorsed the settled view that management and appointments under the 1934 Church Constitution did not violate the claimed religious freedoms or permit a parallel administration. (¶¶ 14–16, 22)
- Article 145(3), Constitution of IndiaA fresh five-judge determination was unnecessary because the asserted religious-rights issue had already been examined and resolved in the governing precedents. (¶ 22)
Held
- The 1934 Church Constitution was valid and binding on the parish church and parishioners. The Court rejected the contention that K.S. Varghese conflicted with earlier Supreme Court decisions; its conclusions were consistent with them. A parallel management could not be created under the claim of the Patriarch’s spiritual supremacy. (¶ 14–16)
- St Mary’s Church was included in the earlier representative litigation. The gift deed placed the church and properties under the Metropolitan’s administration, directly or through representatives, and required the parishioners and managing committee to abide by that authority. The Division Bench’s contrary allocation of appointment powers could not stand. (¶ 17–18)
- The documentary record of appointment and payment of priests, remittances to the hierarchy, representation in the Malankara association and the church’s own conduct confirmed its acceptance of the 1934 Constitution and the Metropolitan’s control. (¶ 19–21)
- The Articles 25 and 26 objection had already been considered in K.S. Varghese. Appointment and management under the 1934 Constitution did not violate those rights; church management was not itself a religious ritual. The demand for a fresh Constitution Bench determination was rejected. (¶ 22)
- The Division Bench judgment contradicted the governing Supreme Court authorities and was set aside; the Metropolitan’s appeals were allowed. (¶ 23)
Result
Appeals allowed; Division Bench judgment set aside. Binding 1934 Constitution and Metropolitan’s authority over the church’s administration and appointments affirmed.