Inheritance And Long Service Cannot Substitute Valid Appointment Process For Temple Pujari: Madhya Pradesh High Court

The Madhya Pradesh High Court has held that long-term service, subsequent recognition, or administrative correspondence cannot validate the appointment of a pujari. [2026 LiveLaw (MP) 273]

The division bench of Justice GS Ahluwalia and Justice Anuradha Shukla further emphasized that the right to serve as a temple priest is neither perpetual nor inheritable. 

"long continuance in service cannot validate the appointment to the post of Pujari nor subsequent recognition or administrative correspondence substitute a valid appointment proceedings. The right to the post of Pujari is neither perpetual in nature not is it inheritable". 

Two Court was dealing with two writ appeals challenging orders of the Single Judge, which had set aside decisions of the Additional Commissioner, Chambal Division, holding that no fresh appointment to the post of pujari of the Vankhandeshwar Mahadev temple was required.

The dispute arose from competing claims over the post of pujari at the Vankhandeshwar Mahadev temple, which is managed by the State Government.

Following the death of the temple's pujari, Ahyodha Prasad, the Sub-Divisional Officer, Bhind, appointed his grandson, Virendra Kumar Sharma, as pujari through an order dated May 10, 1999. An earlier order dated January 10, 1995, had also appointed Rajkumar Sharma alias Raju as pujari after the death of his father, although the record relating to that appointment was no longer traceable.

Anurag Mishra challenged both appointments before the Collector in 2010. While the Collector initiated proceedings to examine the validity of the appointments, the appellants approached the Additional Commissioner, who allowed their revisions and directed the Sub-Divisional Officer to inquire into the matter and proceed in accordance with law.

That order was subsequently set aside by the High Court, which revived the Collector's proceedings and directed the authorities to continue the inquiry from the stage at which it had been left.

Thereafter, the Collector found that none of the parties could produce documents establishing the legality of their appointments. Holding the post to be vacant, the Collector directed the Sub-Divisional Officer to initiate a fresh appointment process in accordance with the State Government guidelines.

The matter, however, continued to travel between the revenue authorities and the High Court through multiple rounds of litigation. In subsequent proceedings, the High Court repeatedly directed the authorities either to conduct a proper inquiry or to proceed with a fresh appointment process in which all eligible candidates could participate.

Despite these directions, the Additional Commissioner, by orders dated December 30, 2025, held that no fresh appointment was required. Those orders were set aside by the Single Judge, leading to the present appeals.

Dismissing the appeals, the Division Bench observed that the repeated directions issued by the High Court had attained finality and that the Additional Commissioner's approach of preserving the existing appointments despite the absence of valid records was unsustainable.

The Court further observed that claims founded on inheritance or long usage of office could not override the requirement of a lawful selection process.

“...the right to the post of Pujari is neither perpetual in nature nor is it inheritable. Further no impropriety can be argued on the basis that earlier orders of appointment were not challenged timely,” the Bench said.

The Court also noted that the appellants appeared to be resisting a neutral appointment process based on old documents because such a process would place them on an equal footing with other aspirants in determining their eligibility and suitability for the post.

Upholding the Single Judge's decision, the Bench reiterated that appointments to the post of pujari in the Vankhandeshwar Mahadev temple could only be made in accordance with the procedure prescribed under the Madhya Pradesh government's circular dated February 4, 2019.

Expressing hope that the authorities would finally resolve the long-pending dispute, the Court observed that they should not yield to claims based on inheritance and long usage of office, but should expeditiously appoint the most suitable candidate in accordance with law.

Accordingly, the appeals were dismissed.

Case Title: Virendra Kumar v Anurag Mishra WRIT APPEAL No. 1737 of 2026, Rajkumar Sharma v Anurag Mishra WRIT APPEAL No. 1738 of 2026

Citation: 2026 LiveLaw (MP) 273

For Appellants: Advocates Prashant Sharma and Nirmal Sharma

For Respondent no 1: Advocate AS Bhadauria 

For State: Goverment Advocate Ravindra Dixit

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