Dera Funds Under Judicial Scrutiny: Punjab & Haryana High Court Allows Production of Bank Records, Upholds Financial Disclosure Directions

Case Name: Sant Jaspal Singh v. Baba Jeet Singh; Baba Jeet Singh @ Sant Baba Jeet Singh v. Sant Jaspal Singh

Date of Judgment: 17 February 2026

Citation: CR-105-2026 & CR-870-2026

Bench: Hon’ble Mr. Justice Virinder Aggarwal

Held: The Punjab and Haryana High Court held that where allegations of mismanagement and misappropriation of funds of a religious institution are specifically pleaded, financial and bank records relating to the institution are directly relevant and cannot be termed irrelevant for the purpose of adjudication. The Court further held that in matters concerning properties of a Dera having public character, limited directions for disclosure of financial statements to safeguard its assets are legally sustainable even in the absence of appointment of a Receiver.

Summary: The common order disposed of two connected revision petitions arising out of Civil Suit No. 311 of 2022 concerning Dera Nirmal Kutiya, Johalan .

The plaintiff had instituted a suit seeking declaration that the defendant had been validly removed as Head of the Dera, along with consequential reliefs including permanent injunction restraining alienation of Dera assets, rendition of accounts, and appointment of a Receiver .

An application was moved by the plaintiff seeking production of various documents including resolutions, income and expenditure records, bank account details of the Dera and the defendant, details of donations, movable and immovable properties, and other financial records. The trial Court, vide order dated 06.08.2025, permitted production of certain limited documents but declined production of bank and financial records (Serial Nos. C to K), holding them irrelevant .

Subsequently, though a bank official from Punjab National Bank had been summoned, the trial Court recalled the summoning order on the ground that once the documents were held irrelevant, the plaintiff could not circumvent that finding by summoning them through the bank .

The defendant also filed a revision against an appellate order dated 16.12.2025, whereby the learned Additional District Judge declined appointment of a Receiver but directed the defendant to furnish detailed financial statements of the Dera, including account statements, monthly income and expenditure, offerings received, and details of assets .

The High Court examined the plaint and noted categorical allegations of mismanagement, misappropriation of Dera funds, purchase of luxury vehicles from Dera funds, and apprehension of unauthorized alienation of properties standing in the defendant’s name. The plaintiff had also specifically sought appointment of a Receiver to manage the Dera’s movable and immovable assets and bank accounts .

In this backdrop, the Court held that financial and property records of the Dera were central to adjudication of the dispute. The trial Court had erred in holding such documents irrelevant. Where allegations pertain to misappropriation of funds and misuse of institutional property, bank statements and account records are directly germane to the lis .

The Court further held that recalling the summoning of the bank official on the premise of irrelevance amounted to curtailing the plaintiff’s right to lead evidence. Questions of admissibility and evidentiary weight are to be assessed at the stage of appreciation of evidence and not at the threshold stage of summoning .

With respect to the appellate direction requiring disclosure of financial statements, the High Court observed that the Dera property does not vest in any individual personally but carries a public character and is to be utilized for welfare of the institution and its followers. The direction to furnish financial details was a protective measure and did not amount to appointment of a Receiver. It was therefore legally sound .

Decision: Revision Petition No. CR-105-2026 filed by the plaintiff was allowed, setting aside the trial Court’s refusal to permit production and summoning of financial records. Revision Petition No. CR-870-2026 filed by the defendant was dismissed. Directions requiring disclosure of financial statements were upheld.