Hindu Adoptions and Maintenance Act, 1956

Section 12(c) - Adoption and Property Rights - Doctrine of Relation Back - The appellant was adopted by defendant No.1, on 16.07.1994, after the death of her husband. The appellant claimed a half share in the suit schedule properties, arguing that he became the legal heir upon adoption. Held, under Section 12(c) of the Act an adopted child cannot divest any person of any estate that vested before the adoption. The court applied the "Doctrine of Relation Back," which states that adoption by a widow relates back to the date of the death of the adoptive father, creating an immediate coparcenary interest in the joint property. However, lawful alienations made by the widow before the adoption are binding on the adopted child. The court upheld the validity of the sale deed executed by defendant No.1 in favor of defendant Nos.2 and 3, as the alienation was made after defendant No.1 had become the absolute owner of the property. The appellant's challenge to the sale deed was dismissed. The court declared the gift deed executed by defendant No.1 in favor of defendant Nos.4 and 5 as null and void. The court found that the gift deed lacked the necessary prerequisites for a valid gift, such as delivery and acceptance of the property. The trial court's decision to grant the appellant the entire 'B' and 'C' schedule properties as the sole legal heir of defendant No.1 was restored. Sri Mahesh v. Sangram, 2025 LiveLaw (SC) 6

Hindu Marriage Act, 1955

Section 13 - Divorce – Cruelty – Desertion – Irretrievable Breakdown of Marriage - Duty of Court: Supreme Court directed that before concluding that a marriage has broken down irretrievably, it is imperative upon the Family Court or the High Court to determine which party is responsible for breaking the marital tie and forcing the other to live separately- A finding of irretrievable breakdown is likely to have devastating effects, especially on children, unless there is cogent evidence for wilful desertion or refusal to cohabit and/or look after the other spouse- The conclusion regarding irretrievable breakdown puts the Courts under an onerous duty to deeply analyse the entire evidence, consider social circumstances, and the background of the parties- The Supreme Court found that the High Court, in granting divorce on the ground of cruelty, failed to advert to the wife's plea that she was thrown out of the matrimonial home and did not undertake the necessary exercise to determine the essential issues- The Supreme Court set aside the High Court's judgment and remitted the matter back to the High Court for a fresh consideration in accordance with the law- Appeal allowed in part. [Paras 4-7] A v. I, 2025 LiveLaw (SC) 1143

Section 13(1)(i-a) – Cruelty – Long Separation as Mental Cruelty - Supreme Court exercised its discretionary power under Article 142 to dissolve a marriage that had been a "legal fiction" for over two decades - The parties had been living separately for 24 years with no children from the wedlock and unsuccessful mediation attempts- Held that where a marriage is wrecked beyond hope of salvage, public interest lies in recognizing the reality rather than keeping parties tied to a dead relationship - Held, a long period of continuous separation without any hope of reconciliation amounts to mental cruelty to both parties - The spouses' strongly held views and refusal to accommodate each other for a long period constitute conduct that makes the matrimonial bond beyond repair - The power to do "complete justice" under Article 142(1) is not fettered by the doctrine of fault and blame applicable to standard divorce petitions under the Hindu Marriage Act - Even if one spouse opposes the dissolution, the Court can grant a divorce if the marriage is irretrievably broken down. [Relied on Shilpa Sailesh vs. Varun Sreenivasan, (2023) 14 SCC 231; Rakesh Raman vs. Kavita, (2023) 17 SCC 433; Samar Ghosh vs. Jaya Ghosh, (2007) 4 SCC 511; Naveen Kohli vs. Neelu Kohli, (2006) 4 SCC 558; Paras 23-33] N v. A, 2025 LiveLaw (SC) 1210 : 2025 INSC 1436

Section 13(1)(ia) & (ib) - Irretrievable breakdown of marriage – Divorce - Supreme Court orders husband to pay Rs. 1.25 crores permanent alimony to his wife while dissolving marriage – Held, there is no possibility of reconciliation between parties and they have been living separately since 15 years - There is no vestige of matrimonial relationship between them and neither party has shown any inclination to resolve their differences - Mediation efforts also failed - Since the respondent-wife and child have not received any financial support from appellant-husband, Rs. 1.25 crores was directed to be paid - Appeal allowed. [Paras 5-9] X v. Y, 2025 LiveLaw (SC) 813 : 2025 INSC 978

Section 13B - Settlement Agreement - Mutual Consent Divorce- Withdrawal of consent - Supreme Court acknowledged that the respondent-wife's withdrawal from the mutual consent divorce agreement at the second motion was a valid exercise of her statutory right - Held that subsequent demand of wife for a higher alimony demonstrated an intention to coerce a better settlement, and her allegations of coercion, misrepresentation, and fraud regarding the initial settlement were unsubstantiated. [Para 18] A v. State of Maharashtra, 2025 LiveLaw (SC) 773 : 2025 INSC 926

Whether the definition of "dependent" as per Section 2(1)(d)(ii)(d) of the Act, specifically whether widowed sisters of the deceased, who were not minors, could be considered dependents entitled to compensation – Held, Section 2(1)(d)(ii)(d) of the 1923 Act defines dependents to include a "minor brother, or an unmarried sister, or a widowed sister if a minor" and noted the incongruity with present-day realities, referring to the context of the Hindu Marriage Act, 1955, which makes the occurrence of a "widowed minor sister" unlikely - Supreme Court declined to interfere with the High Court judgment which treated widowed adult sisters as dependents, allowing compensation - Supreme Court left the question of law about the definition of "dependent" open and recommended the Law Commission of India to consider suitable amendments to the Employees Compensation Act to reflect current social realities. [Paras 2 - 6] New India Assurance Company Ltd. v. Kogga, 2025 LiveLaw (SC) 1039

Hindu Minority and Guardianship Act, 1956

Section 6(a) - Custody of Minor Child - Welfare of Child - Supreme Court while upholding the High Court's order placing the minor son, who is above five years of age, in the custody of his father, rejected the mother's appeal, noting that the custody issue had not been finally closed and the mother could pursue her remedies under relevant statutes - Noted that the child is a male child and is now aged above five years - Noted that the child was not willing to part company with his father - The fact that both parents are working and cannot always be physically with their children should not be a ground to place custody with one who may be temporarily working from home - It is a matter of common knowledge that married couples work to secure better education and future for their ward - Rejected the notion that a parent working from home provides better care than one who visits the office - The distance from home to school as "not a relevant consideration" particularly when both parties reside in the National Capital Region and the child is travelling for "better education."- Travel time being a few minutes less or more "hardly matters" - Noted that the child continues to be a student at the same school (Heritage School), and his education is not disturbed - The father has elder family members at home, including grandfather, who are giving company to the child - Considering the overall welfare, the male child being above five years old and continuing in the same school with no desire to part from his father, Supreme Court did not find a reason to interfere with the High Court's order. [Paras 7 - 14] Poonam Wadhwa v. Ajay Wadhwa, 2025 LiveLaw (SC) 1165

Section 8(2) and (3) - Voidable transaction - Repudiation by Minor – Held, disposal of immovable property by a natural guardian in contravention of sub-Section (1) or sub-Section (2) of Section 8 (i.e., without the previous permission of the court) is voidable at the instance of the minor or any person claiming under him - It is not mandatory for a minor, upon attaining majority, to file a suit for the cancellation of a sale deed executed by their natural guardian in contravention of Section 8(2) of the Act - A voidable transaction executed by the guardian of the minor can be repudiated and ignored by the minor within the prescribed time on attaining majority either by instituting a suit for setting aside the voidable transaction or by repudiating the same by his unequivocal conduct - Avoidance or repudiation by conduct is permissible because - i. The minor may not be aware of the transaction and thus not in a position to institute a suit; ii. The transaction may not have been given effect to, and the party acquiring the right may not have possession, giving the impression that the property is intact in the minor's hands, making a suit seem unnecessary - Transferring the property himself on attaining majority within the prescribed time period is an example of an implied repudiation by conduct - Noted that such an act is sufficient to repudiate the earlier sale deed executed by the father/guardian - The effect of avoidance is that the voidable transaction becomes void from its very inception, and the avoidance relates back to the date of the transaction - Appeal allowed. [Relied on Madhegowda vs Ankegowda (2002) 1 SCC 178; G. Annamalai Pillai vs District Revenue Officer and Ors. (1993) 2 SCC 402; Paras 11-14, 22, 32, 34] K.S. Shivappa v. K. Neelamma, 2025 LiveLaw (SC) 981 : 2025 INSC 1195

Hindu Succession Act, 1956

Suit for Partition and Separate Possession - Validity and Effect of Release Deeds – Admissibility of Unregistered Partition Deed (Palupatti) for Collateral Purposes – Computation of Shares under Hindu Succession Act, 1956 (Unamended Section 6) – Held, a registered relinquishment deed releasing share of a coparcener in the joint family property, operates immediately regardless of its implementation - Supreme Court set aside the concurrent findings of the High Court and Trial court, which refused to consider the Appellant's exclusive share in the suit property, despite there being a registered relinquishment deeds by Appellant's two brothers releasing their respective shares in Appellant's favor, and a subsequent family settlement (palupatti) in 1972, which formally recorded the separation of the remaining coparceners and delineated their respective shares, which had been independently managed ever since - A family arrangement recorded in writing, when relied upon only to explain how the parties thereafter held and enjoyed the properties, does not require registration for that limited collateral use - Appeal allowed. [Relied on Elumalai v. M. Kamala [(2023) 13 SCC 27; Thulasidhara v. Narayanappa [(2019) 6 SCC 409; Paras 7-9] P. Anjanappa v. A.P. Nanjundappa, 2025 LiveLaw (SC) 1074 : 2025 INSC 1286

Section 2 (2) – Applicability to Scheduled Tribes – Held, HSA does not apply to members of STs - Section 2(2) of the HSA, 1956 explicitly states that nothing contained in the Act shall apply to the members of any Scheduled Tribe within the meaning of clause (25) of Article 366 of the Constitution, unless the Central Government, by notification in the Official Gazette, otherwise directs - The words of the section are explicit, and the HSA, 1956, cannot apply to Scheduled Tribes - Supreme Court set aside High Court's order directing that daughters in tribal areas in the state of H.P. shall inherit property in accordance with HSA and not as per customs and usages - High Court's directions were beyond the scope of the appeal, as the issue was neither directly nor substantially involved in the intra-party appeal, and the directions were not emanating from any of the issues framed or pleas raised by the parties - Set aside order of High Court. [Relied on Tirith Kumar & Ors. vs. Daduram & Ors., (2024) SCC OnLine SC 3810; Paras 4-6] Nawang v. Bahadur, 2025 LiveLaw (SC) 1025

Section 29, 8 - Locus standi of State - Validity of will - Rajasthan Escheats Regulation Act, 1956 - Probate of will – Held, State cannot invoke Doctrine of Escheat to challenge a will which is granted probate - Government is a stranger to the property when a Hindu hireless male dies with a will - The state's locus standi to assail the probate grant was negated by the Court, as the case involved testamentary succession, not intestate succession attracting Section 29 of HAS - The Court emphasized the doctrine of escheat under section 29 applies only when an intestate leaves no heir qualified under the HAS - It has to be ascertained as to whether there are any Class1 or Class 2 heirs, agnates or cognates - Only on the failure of any qualified heir being present to succeed to the properties, under the HAS Act, Section 29 of the said Act would apply as it would be a case of failure of heirs - Since probate was granted by the High Court, the legatees under the will, had the right to succeed - Held that it is only in the event of intestate succession. Section 29 of the HAS Act applying that there would be a devolution of the estate of a deceased male Hindu on the government and not otherwise - Supreme Court imposed Rs. 1 lakh each on Petitioners for suppression and clarified that only heirs or persons entitled to succeed could seek revocation under Section 263 of Indian Succession Act, if probate was wrongfully granted. Appeal dismissed. [Paras 5 - 6] State of Rajasthan v. Ajit Singh, 2025 LiveLaw (SC) 906

Section 2(2) - Applicability to Scheduled Tribes (ST) - Customary Law - Justice, Equity and Good conscience - Article 14, 15, 38, 46 of the Constitution of India – Issue - Whether a tribal woman or her legal heirs are entitled to an equal share in her ancestral property - Trial Court and High Court dismissed the suit filed by appellant (heirs of a tribal woman) citing that mother had no right in her father's property as members of Scheduled Tribe are not governed by the Hindu Succession Act, 1956 as per section 2(2) and nothing proved by custom - This Court Held - Exclusion of female from inheritance is unreasonable and discriminatory - that Hindu Succession Act is not applicable to the Scheduled Tribes, it does not mean that tribal women are automatically excluded from inheritance - it needs to be seen by Court whether there exists any prevailing custom restricting the female tribal right to share in the ancestral property - In this case parties could not establish the existence of any custom which excluded women from inheritance - Customs are too like the law, cannot remain stuck in time and others cannot be allowed to take refuge in customs or hide behind them to deprive others - Held in absence of any specific tribal custom or codified law prohibiting women's right, courts must apply “justice, equity and good conscience” - Where there is no custom prohibiting succession to women, still denying them succession is in violation of Article 14, 15 read with Articles 38 and 46, ensuring that there is no discrimination against women. Held legal heirs of tribal woman entitled to share in the property, set aside order of High Court. Appeal allowed. [Relied on Western U.P. Electric Power and Supply Co. ltd. v. State of U.P., (1969) 1 SCC 817; Para 13, 19, 20, 21] Ram Charan v. Sukhram, 2025 LiveLaw (SC) 717 : 2025 INSC 865

Hindu Religious and Charitable Endowments

Validity of the laws relating to Hindu Religious and Charitable Endowments of the States of Tamil Nadu, Andhra Pradesh and Telangana - Petitioners sought declaration of provisions as ultra vires Articles 14, 19, 25, 26, 29, and 31A – Held, Challenges to state-specific legislation more effectively addressed by respective High Courts due to distinct legislative schemes and sociocultural contexts. Liberty granted to petitioners to approach jurisdictional High Courts. High Courts advised to consider historical, socio-economic, and religious aspects and may constitute Expert Committees. Writ petitions disposed of. (Para 4 – 8) Sh.Dayanand Saraswati Swamiji v. State of Tamil Nadu, 2025 LiveLaw (SC) 413 : 2025 INSC 465

Joint Family Property

Power of Karta to alienate Joint Family Property - Legal necessity - Onus to proof - Supreme Court reiterated that the Karta of a Hindu undivided Family (HUF) has the power to alienate joint family property for legal necessity or benefit of estate, and such sale binds the interests of all undivided members, including minors and widows - The discretion of the Karta in determining legal necessity is wide and each case turns into its facts - Noted that family necessities may include payment of government revenue, marriage expenses (of male coparceners or daughters), maintenance, necessary litigation to recover property, funeral expenses, and debts for family business - The existence of legal necessity must be judged on the facts and circumstances of each case - Appeal allowed. [Paras 11, 20, 21] Dastagirsab v. Sharanappa @ Shivasharanappa, 2025 LiveLaw (SC) 915 : 2025 INSC 1120

Partition - Family Settlement - Oral family settlement - Registered will - Where a will distributes properties in defines proportions among family members and an oral family settlement also distributes properties in almost the same properties and there is material to establish that the testator anticipated conflicts and divided properties to avoid them - Then the existence and persuasive nature of the oral family settlement can be countenanced - especially when supported by the fact of possession of the properties - Supreme Court upheld genuineness of will [Paras 9,10-12] Metpalli Lasum Bai v. Metapalli Muthaih, 2025 LiveLaw (SC) 734 : 2025 INSC 879

Will - Registered Will - Proof of execution - Presumption of Genuineness - Burden of Proof – Held, a registered will carries a presumption of genuineness - The burden of proof to establish that a registered will was not executed as alleged or that suspicious circumstances render it doubtful, lies on the party disputing its existence. The genuineness of the registered will was beyond doubt - Set Aside order of High Court and restored order of Trial Court - Appeals allowed. [Para 9] Metpalli Lasum Bai v. Metapalli Muthaih, 2025 LiveLaw (SC) 734 : 2025 INSC 879

Partition of Joint Family Property – Self-Acquired Property – Whether the suit property, acquired by Defendant No. 1 post-partition, was ancestral (joint family) or self-acquired property. Held, upon partition of joint Hindu family property, shares allotted to coparceners become their self-acquired property, with absolute rights to sell, transfer, or bequeath. No presumption exists that property is joint family property merely due to the existence of a joint Hindu family; the claimant must prove it is joint family property, typically by showing a joint family nucleus used for its acquisition. Ancestral property is limited to that inherited from paternal ancestors within three generations. The doctrine of blending requires clear intention by the owner to relinquish self-acquired property into the joint family pool; mere use by family members or acts of generosity do not suffice. Here, Defendant No. 1's purchase of his brother's share post-partition, using a loan and not joint family funds, established the property as self-acquired. The subsequent sale to the Appellants was valid. The High Court's judgment, invalidating the sale by misapplying the doctrine of blending and overlooking evidence of independent acquisition, was set aside. Appeal allowed; suit property held to be self-acquired by Defendant No. 1, and sale to Appellants upheld. (Paras 13 - 20) Angadi Chandranna v. Shankar, 2025 LiveLaw (SC) 494 : 2025 INSC 532

Temple

Cochin Devaswom Board - License fee – Held, appellants herein only challenged specific fee enhancement orders - By directing fresh fixation and inquiry, High Court introduced new issues outside the pleadings, in violation of judicial discipline and the principle of natural justice, as the appellants were not put to notice before passing an adverse direction against them - If without putting parties on notice, the Court travels beyond the scope of the petition, takes parties by surprise and makes any strong observations and directions, it will create a chilling effect on other prospective litigants too - Even if in exceptional case, Court feels the need to travel beyond the scope of writ petition and make observations, the least a party is entitled to, is an opportunity to explain and defend themselves - The High Court exceeded its jurisdiction - Appeal allowed. [Relied on Pradeep Kumar v. Union of India, (2005) 12 SCC 219; Ashok Kumar Nigam v. State of U.P., (2016) 12 SCC 797; Paras 23-32] P. Radhakrishnan v. Cochin Devaswom Board, 2025 LiveLaw (SC) 970 : 2025 INSC 1183

In a 24-year dispute over the ownership and control of the iconic Hare Krishna Hill temple complex in Bengaluru (approximately 6 acres of land allotted by the Bangalore Development Authority in 1988), the Supreme Court upheld the independent legal status of the International Society for Krishna Consciousness, Bangalore ("ISKCON Bangalore"), registered under the Karnataka Societies Registration Act, 1960. The Court set aside the Karnataka High Court's 2011 judgment favoring the International Society for Krishna Consciousness, Mumbai ("ISKCON Mumbai"), a public trust registered under the Societies Registration Act, 1860, and the Bombay Public Trusts Act, 1950, restoring the trial court's 2009 decree declaring ISKCON Bangalore as the absolute owner and restraining ISKCON Mumbai from interference. The ruling emphasizes the primacy of statutory registration and title over affiliative claims, dissolving a long-standing oversight committee and closing the chapter on intra-organizational litigation. International Society For Krishna Consciousness, 2025 LiveLaw (SC) 589 : 2025 INSC 717

Interim Arrangement for temple management (Maa Chandi Devi Temple) - Supreme Court remands the matter to High Court & directs Collector, Haridwar to conduct a personal inquiry into the management of the Math and submit a report to the High Court - Interim arrangement made by High Court to remain in effect - Remanded matter to High Court. [Paras 7-10] Mahant Bhawani Nandan Giri v. State of Uttarakhand, 2025 LiveLaw (SC) 817

ISKCON Mumbai, founded in 1966 by Srila Prabhupada with its registered office in Juhu, Mumbai, claimed ISKCON Bangalore (registered July 1978) operated solely as its subordinate branch, with all properties vesting in Mumbai. - ISKCON Bangalore acquired the disputed Hare Krishna Hills property (Schedule 'A') via allotment to it specifically, constructing the temple using devotee funds; it sought declarations of independent ownership, administrative autonomy, and injunctions against Mumbai's interference in a suit filed in 2001 (Suit No. 7934/2001, City Civil Court, Bengaluru). Trial court decreed in favor of ISKCON Bangalore on April 17, 2009, rejecting Mumbai's counterclaim for injunction. Karnataka High Court, on May 23, 2011, reversed this, holding ISKCON Bangalore as a branch and vesting title in Mumbai, prompting ISKCON Bangalore's appeal to the Supreme Court. An oversight committee under former Justice R.V. Raveendran supervised temple affairs for 14 years per interim Supreme Court orders. Issues 1. Whether ISKCON Bangalore constitutes an independent juristic entity or merely a branch of ISKCON Mumbai, affecting property vesting and administrative control. 2. Ownership and title to the Hare Krishna Hill temple property, allotted explicitly to ISKCON Bangalore—does it vest in the allottee society or the alleged "parent" trust (ISKCON Mumbai)? 3. Validity of the July 1, 1984, General Body meeting electing Madhu Pandit Dasa and others as ISKCON Bangalore's governing body, challenged by Mumbai faction. Held, Allowed the appeal filed by ISKCON Bangalore; set aside the Karnataka High Court's May 23, 2011, judgment and restored the trial court's April 17, 2009, decree in full. Declared ISKCON Bangalore the absolute owner and possessor of the Hare Krishna Hills property; ISKCON Mumbai has no title, control, or authority to interfere in its administration or remove office-bearers. Upheld the 1984 General Body election as valid, dismissing challenges by the Mumbai faction (represented by earlier members like Amiya Vilas Swami). Directed dissolution of the R.V. Raveendran oversight committee within one month of the judgment. No costs awarded; urged both parties to resolve future disputes amicably, noting the Hare Krishna movement's spiritual ethos should preclude such litigation. International Society For Krishna Consciousness, 2025 LiveLaw (SC) 589 : 2025 INSC 717

Modifying the Allahabad High Court's order dated November 8, 2023, which had barred the use of temple funds for land acquisition, the Supreme Court permitted the State of Uttar Pradesh to utilize fixed deposits held in the name of Shri Banke Bihari Ji Temple (Vrindavan) to purchase approximately 5 acres of land for developing a ₹500 crore corridor around the temple. The Court mandated that the acquired land be registered solely in the name of the deity or the temple trust, ensuring the funds' proceeds remain dedicated to the temple's perpetual benefit. The ruling was prompted by the urgent need for infrastructure overhaul in Mathura and Vrindavan—key pilgrimage sites attracting millions annually—following incidents like the 2022 stampede at the temple, which highlighted maladministration and safety risks. Citing the Uttar Pradesh Braj Planning and Development Board Act, 2015, the Court underscored the State's statutory duty to prioritize heritage conservation, devotee amenities (e.g., parking, roads, dharamshalas, hospitals, toilets, and security posts), and beautification of sites like Yamuna River ghats and Kusum Sarovar. Development was deemed a collective responsibility involving government, temple trusts, and communities to facilitate safe, spiritually enriching pilgrimages without discomfort. Ishwar Chanda Sharma v. Devendra Kumar Sharma, 2025 LiveLaw (SC) 576 : 2025 INSC 700

Temple Administration - Supreme Court appoints Ex-Allahabad HC Judge Ashok Kumar as Head of Committee to administer Bankey Bihari Temple - Supreme Court modifies previous order regarding the use of temple funds for land acquisition, restoring the position to status quo ante, where the State cannot use temple funds for land acquisition - Stays operation of the ordinance's provisions that grants the State powers to constitute a Trust for managing the temple's affairs, specifically Sections 3 & 5, until the validity of the Ordinance is resolved by the High Court - Supreme Court directs establishment of a High-powered Temple Management Committee to oversee the day-to-day functioning of the Thakur Shree Bankey Bihari Ji Maharaj Temple, noting the ineffectiveness of previous management - The Committee is tasked with planning the holistic development of the Temple and its vicinity, including privately negotiating and land purchases or directing the State Government to acquire land - Held that apart from 4 Goswami members on the Committee, no other Goswami or sevayat is permitted to interfere in the Temple's critical functions, except for puja/sewa and offering prasad to the deity - Supreme Court stays operation and further proceedings of Single judge of High Court in a matter concerning the Ordinance's constitutionality to avoid parallel proceedings, requesting the Chief Justice of High Court to list such petitions before a Division Bench. [Paras 16-36] Management Committee of Thakur Shree Bankey Bihari Ji Maharaj Temple v. State of Uttar Pradesh, 2025 LiveLaw (SC) 785

Temples and Religious Practices - Interim Relief Granted - Supreme Court grants interim relief in a Petition for Special Leave to Appeal, directing the Respondents to continue performing the Udayasthamana Pooja at the Guruvayur Sree Krishna Temple on Vrishchikam Ekadasi (01.12.2025), strictly in accordance with the temple's tradition and without any change - Any ritual which has become a long-standing tradition and assumed religious significance "ought not be unsettled on the apprehension that there would be potential public inconvenience"- The "faith of the worshippers at large ought not to be put aside on the anvil of managerial and administrative concerns and must be given precedence and respect as far as possible" - Inconvenience to the public cannot be a ground to discontinue / alter the rituals / pooja to be performed on the sacred day for the deity. [Paras 5 - 8] P.C. Hary v. Guruvayoor Devaswom Managing Committee, 2025 LiveLaw (SC) 1055