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Shree Shree Ram Janki Ji Asthan Tapovan Mandir & Anr. v. The State of Jharkhand & Ors.

Civil Appeal · 2019 INSC 609Decided 1 May 2019
Civil Appeal No. 4003 of 2019
Dr. Justice D.Y. Chandrachud · Justice Hemant Gupta

Background

A trust managing the Shree Ram Janki Tapowan Mandir deity's land in Ranchi had its original 1948 and 1987 trust deeds (which barred sale of the deity's property) superseded by a fresh 2005 deed permitting transfers, under which some land was sold. A member of the public filed a Public Interest Litigation in the Jharkhand High Court alleging the land had been fraudulently and illegally transferred in collusion with government officials, without having first lodged any police complaint. The High Court, forming a prima facie view that the deity's land could never be transferred, directed the CBI to investigate the matter, and the trust and the temple priest challenged that direction before the Supreme Court.

Decision Breakdown

The Supreme Court held that directing a CBI investigation is an extraordinary power that constitutional courts may use only rarely and in exceptional circumstances, such as where there is a clear prima facie case, a need to instil public confidence, or matters of national importance, relying on the Constitution Bench ruling in State of West Bengal v. Committee for Protection of Democratic Rights and later decisions. It found the High Court's reasoning legally untenable: there was no police complaint, no proper finding of fraud (only "casual" observations), and the underlying dispute, whether trustees could lawfully sell the deity's land, was a civil property dispute, not evidence of a criminal offence merely because government officials had granted permissions. Holding that the High Court had exceeded its jurisdiction and made unwarranted sweeping remarks against the State Government, the Supreme Court allowed the appeal, set aside the High Court's order, and dismissed the underlying writ petition.

Lesson Learnt

Courts cannot order a CBI investigation as a routine response to allegations in a public-interest petition; that extraordinary step requires concrete prima facie material of a criminal offence, and a genuinely civil dispute (like a trust's power to sell property) should not be converted into a criminal investigation just because government officials were involved in approvals.

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

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