Case Summary: Most Rev. P.M.A. Metropolitan vs Moran Mar Marthoma (1995)
Citation: AIR 1995 SC 2001: (1995) 5 JT 1: (1995) 4 SCALE 760: (1995) 4 SCALE 1: (1995) 4 SCC 286 Supp: (1995)
4 SCC 286: (1995) 1 SCR 542 SuppCase No: Civil Appeals Nos. 4958-60 of 1990, etc.
Date of Decision: 20-06-1995
Appellant: Most Rev. P.M.A. Metropolitan and others
Respondent: Moran Mar Marthoma and another
Bench: Justice S.C. Sen, Justice R.M. Sahai, Justice B.P. Jeevan Reddy (Full Bench)
Final Decision: Disposed Off
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Law Points Raised
1. Maintainability of suit under Section 9 of CPC in ecclesiastical disputes.
2. Application of res judicata to previous decisions involving church factions.
3. Interpretation of rights under Articles 25 and 26 of the Constitution regarding religious denominations.
4. Scope and impact of the Places of Worship (Special Provisions) Act, 1991.
5. Jurisdiction of civil courts in religious and temporal matters of the Church.
Ratio Decidendi
The Court held that civil courts have jurisdiction under Section 9 CPC in matters involving church property and temporal control, even if they are rooted in religious disputes. The judgment clarified that historical compromises and reconciliations between factions do not bar litigation under res judicata if new causes of action arise. Religious groups cannot claim unfettered autonomy in administrative matters if they impact civil rights or public interest.
Final Ruling
The appeals were disposed of with clarifications on maintainability, historical context, and constitutional rights. The Supreme Court emphasized that spiritual unity must not be hijacked by administrative ambitions and legal battles for control over church assets.
Relevant Paragraph Numbers
Key references: Paragraphs 1–2 (background of prolonged dispute), Paragraphs 3–5 (Christian church history and origins), Paragraphs 6 onwards (legal issues on CPC, Constitution, and Places of Worship Act).
Summary
This case encapsulates a century-old dispute between factions within the Malankara Jacobite Syrian Church over administrative control, religious identity, and church property. While respecting the sanctity of religious beliefs, the Court reaffirmed the power of civil courts to adjudicate temporal disputes. It urged an end to litigation in matters of faith and called for resolution through unity, warning against continued strife for control of church wealth and power.
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