Supreme Court Upholds Hereditary Pujari Rights Based on Revenue Records and Long Possession

Case Name: Ogeppa (Dead) through LRs. & Others v. Sahebgouda (Dead) through LRs. & Others

Citation: 2026 INSC 191; Civil Appeal Nos. 7181–7182 of 2016

Date of Judgment/Order: 25 February 2026

Bench: Hon’ble Mr. Justice Prashant Kumar Mishra and Hon’ble Mr. Justice K. Vinod Chandran

Held:The Supreme Court held that hereditary pujari rights in a temple can be established through consistent documentary evidence, revenue records, admissions of the opposing party, and long-standing performance of religious duties. Where the courts below have recorded concurrent findings of fact based on such evidence, the Supreme Court, exercising jurisdiction under Article 136 of the Constitution, will not interfere unless those findings are manifestly perverse.

Summary: The dispute concerned the hereditary right to perform puja and manage religious ceremonies at the Amogasidda temple located in Mamatti Gudda, Jalgeri, Karnataka. The respondents claimed that their family had been the ancestral wahiwatdar pujaries of the temple for generations, performing daily worship and conducting the annual jatra while receiving offerings from devotees. The appellants contested this claim, asserting rights based on a decree obtained by their predecessor in 1901. The litigation history spanned more than a century, including multiple suits and appeals beginning in 1944. In the present proceedings arising from Original Suit No. 56 of 1982, the Trial Court partly decreed the suit by recognising both parties as pujaries. However, the First Appellate Court reversed this finding and declared the respondents to be the hereditary pujaries. The High Court affirmed the appellate decision after remand by the Supreme Court. Examining the record, the Supreme Court noted that the appellants’ reliance on the 1901 decree was undermined by their own predecessor filing a suit in 1944 seeking possession of the temple, thereby indicating that they were not in possession at that time. The Court also emphasised that the appellants failed to institute a fresh suit despite obtaining liberty to do so in 1946, which weakened their claim. The revenue records reflected grants of land to the temple connected with the respondents’ family, and admissions by the appellants’ own witness acknowledged cultivation of such lands by the respondents. Considering these factors, the Court held that the respondents had successfully established their hereditary pujari rights through documentary evidence and long-standing practice.

Decision: The Civil Appeals were dismissed, the judgment of the High Court affirming the declaration of the respondents as hereditary pujaries of the Amogasidda temple was upheld, and no order as to costs was passed.