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Prasannatma Das v. K.N. Haridasan Nambiar (Dead) and Others

Civil Appeal · 2025 INSC 717Decided 16 May 2025
C.A. No.-003821-003822 - 2023 (with connected appeals C.A. Nos. 9313/2014, 9314-9315/2014, 9311-9312/2014, 9307-9308/2014, 9305-9306/2014, 9309-9310/2014 and 9316/2014)
Justice Abhay S. Oka · Justice Augustine George Masih

Background

Two Hare Krishna (ISKCON) societies, ISKCON Mumbai and ISKCON Bangalore, were locked in a decades-long dispute over who legitimately controlled ISKCON Bangalore's governing body. The dispute originated in two civil suits (Suit No. 1758 of 2003 and Suit No. 7934 of 2001) filed in Bangalore courts, with rival factions each claiming to have been validly elected at a General Body Meeting held on 1 July 1984. The litigation, which also spawned a contempt petition and a criminal case, dragged on for more than 20 years across trial court, first appeal, and now the Supreme Court.

Decision Breakdown

The Supreme Court found that the plaintiffs (one faction) had produced no evidence to substantiate their claim to have been validly elected, whereas both the Trial Court and the High Court had accepted the rival faction's case based on the 1 July 1984 meeting. Finding no error in the concurrent findings of fact by the lower courts, the Court dismissed Civil Appeal Nos. 3821-3822 of 2023, while allowing a connected appeal (No. 9313 of 2014) by restoring an earlier trial court decree that had been overturned by the High Court. The remaining connected appeals were disposed of as not surviving in light of these findings, the related contempt petition was not proceeded with, and an FIR connected to the dispute was quashed. The Court also directed dissolution, after one month, of a court-appointed oversight committee headed by a former Supreme Court judge.

Lesson Learnt

In civil litigation, a party's bare assertions are not enough. Courts decide disputed facts (such as who was validly elected to a governing body) based on the evidence actually placed on record, and appellate courts are reluctant to disturb concurrent factual findings of the trial court and High Court where no evidence was led to rebut them.

Official source (sci.gov.in)View Judgment (PDF)

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