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Legal Case Shots

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Constitutional LawSupreme Court of India

M. Siddiq (D) Thr. LRs. v. Mahant Suresh Das & Ors. (The Ayodhya / Ram Janmabhoomi-Babri Masjid Title Dispute)

Civil Appeal · 2019 INSC 1231Decided 9 Nov 2019
Civil Appeal Nos. 10866-10867 of 2010
Chief Justice Ranjan Gogoi · Justice S.A. Bobde · Dr. Justice D.Y. Chandrachud · Justice Ashok Bhushan · Justice S. Abdul Nazeer

Background

This is the final judgment in the decades-old Ayodhya title dispute over a roughly 2.77-acre site in Ayodhya, Uttar Pradesh, where a structure known as the Babri Masjid stood until its demolition in 1992. Four connected civil suits were before the Court: one by a Hindu worshipper seeking a right to pray, one by Nirmohi Akhara claiming management rights as the shebait (custodian), one by the Sunni Central Waqf Board and Muslim parties claiming title to the mosque, and one filed on behalf of the Hindu deity Ram Lalla Virajman and the "Janmasthan" claiming the land as the birthplace of Lord Ram. The Allahabad High Court had earlier ordered a three-way division of the site between the Hindu and Muslim parties and Nirmohi Akhara, which none of the parties were fully satisfied with, leading to cross-appeals before the Supreme Court.

Decision Breakdown

After an extensive 1,045-page examination of historical, archaeological, and testimonial evidence (including the 2003 Archaeological Survey of India excavation report), the Court held that Nirmohi Akhara's suit was barred by limitation and its claim to be a "shebait" was rejected, while the Sunni Central Waqf Board's and the deity's suits were held to be within time. The Court found that the evidence did not establish exclusive possession by the Muslim parties over the inner courtyard, while the Hindu parties had long-standing, continuous belief and worship establishing their claim, and granted a decree in favour of the plaintiff deity Ram Lalla for the entire disputed site. Exercising its special power under Article 142 of the Constitution "to do complete justice," the Court directed the Central Government to set up a trust within three months to manage the disputed site and facilitate construction of a temple, while separately directing that an alternative 5-acre plot be allotted to the Sunni Central Waqf Board at a prominent location in Ayodhya for construction of a mosque, and that Nirmohi Akhara be given an appropriate role in managing the new trust. A separate addendum (by an unnamed judge, with the agreement of the rest of the bench) examined the specific historical/faith question of whether the disputed structure was believed to be Lord Ram's birthplace.

Lesson Learnt

This case shows the Supreme Court's broad constitutional power under Article 142 to craft a practical, complete resolution, including allotting substitute land to a losing party, when ordinary property-law remedies alone would not do full justice between all stakeholders in an exceptionally long-running, high-stakes dispute.

M. Siddiq (D) Thr. LRs. v. Mahant Suresh Das & Ors. (The Ayodhya / Ram Janmabhoomi-Babri Masjid Title Dispute) – Legal Case Shots | LegalAware