Friend of god: Ayodhya -Babri dispute case

Author: Saachi Singh, a Student of Symbiosis Law School, Hyderabad



The concept of juristic persons, often referred to as legal entities or artificial persons, in the legal system are corporations to deities and rivers to animals; the notion of juristic persons extends the scope of legal personality to entities that may not possess physical form but nonetheless play significant roles in society. This article delves into the multifaceted realm of juristic persons, exploring its historical roots, legal representation and cultural and societal recognition, especially its nuanced form called “next friend” or “friend of god”. Through examining key legal cases, historical developments, and cultural practices, the aim to shed light on the diverse range of entities considered juristic persons and the rights and obligations associated with this designation.


Juristic persons, also known as legal persons or artificial persons, are entities recognised by the court, having similar obligations and rights as those of natural persons (human beings); these entities, despite lacking a physical form or natural existence, are treated naturally under law. They can be corporations; in the case of Salomon v. Salomon & Co. Ltd. (1897), it affirmed the doctrine of corporate personality: a company is a separate legal entity distinct from its shareholders, the House of Lords held that the company was indeed a distinct legal person, separate from its shareholders, and therefore Mr. Salomon was not personally liable for the company’s debts. They can be god and deities; in the case of Shiromani Gurdwara Parbandhak Committee vs Som Nath Dass and Others, the Supreme Court of India affirms the legal recognition of juristic persons in India, underscoring their distinct status as artificially formed entities with rights and responsibilities conferred by law, the case revolves around the Shiromani Gurdwara Parbandhak Committee (SGPC), a statutory body responsible for managing Sikh religious shrines in Punjab, and a dispute over the ownership of gurdwara properties, it addressed the legal status of the Guru Granth Sahib and its implications for managing gurdwara properties. It signifies a departure from the traditional understanding of legal personhood limited to natural individuals, highlighting the law’s adaptability in accommodating the complexities of modern society. 

In Indian law, deities are considered individuals with legal personality, akin to trusts and firms. This particular gives recognition to the contest their own legal cases, albeit with the assistance of a human representative. The role of this representative plays a crucial recognition in the interest of the deity in court proceedings. The recognition of deities as juristic persons traces its roots back to British colonial rule in India. British administrators classified temples as legal entities, with deities considered the rightful owners of temple property. The recognition of deities as juristic persons traces its roots back to British colonial rule in India. British administrators classified temples as legal entities, with deities considered the rightful owners of temple property. In ancient Hindu legal texts like Dharmashastras, temples were considered divine property, and deities were understood as holding ownership rights. However, the concept of juristic personality wasn’t explicitly articulated in the same way as under British rule. British administrators codified and formalised the existing notion of temple property belonging to deities. They recognised deities as “juristic persons” within the legal framework for managing religious endowments. This allowed temples to sue and be sued, enter contracts, and hold property. Landmark cases, such as Bishwanath vs. Shri Thakur Radhaballabhji & Others and Dakor Temple case, established legal precedents affirming the juridical status of Hindu idols and the pious ideals they represent. These cases elucidated the rights of deities as juristic persons, including the capacity to accept gifts, hold land, and pursue legal remedies through representation in court. The Uttarakhand High Court Judgement (2017) also reaffirms the notion regarding the Rivers Ganga, and Yamuna declaring them juristic persons, highlighting the broader debate about granting legal rights to nature.

In the case of Ayodhya Case (Ram Lalla Virajman & Ors. v. M. Siddiq & Ors.) (2019), the deity “Ram Lalla Virajman” was named as a plaintiff in the case, represented by legal guardians, as the deity was seen as a minor, the legal concept of “next friend” was used by the first representative of the deity, retired High Court Judge Deoki Nandan Agarwal, from Code of Civil Procedure (CPC) in India, the “next friend” concept refers to a legal mechanism allowing a minor or a person of unsound mind to participate in legal proceedings through a representative. In January 2024, the Supreme Court observed that Ram Lalla Virajman “being an idol, cannot have a ‘next friend’ within the meaning of the Civil Procedure Code”. So the concept of “friend of god” or “Sakha” (formulated by Deoki Nandan Agarwal), was used instead. Justice D V Sharma had said in the 2010 Allahabad HC judgment in the Ayodhya title suit: “As in the case of a minor, a guardian is appointed, so in the case of an idol, a Shebait or manager is appointed to act on its behalf.” Deoki Nandan Agarwal, a retired judge of the Allahabad High Court, played a pivotal role as the next friend of Ram Lalla, asserting the deity’s claim to the disputed land in Ayodhya. Agarwal’s dedication and legal expertise laid the groundwork for subsequent legal battles surrounding the ownership of the site.

The next friend of god, Thakur Prasad Verma, represented Ram Lalla Virajman in court from 1996 to 2009. He worked as a professor at Banaras Hindu University and utilised his knowledge of history and archaeology to push the case forward. His scholarly contributions and commitment to the cause of the deity were instrumental in advancing the legal proceedings. Then, the last friend of god, Triloki Nath Pandey, a VHP office-bearer, continued to represent the deity’s interests in court, contributing to the ongoing legal battle over the ownership of the disputed land in Ayodhya.

In conclusion, the concept of juristic persons, encompassing entities such as corporations, deities, and even natural elements like rivers, highlights the adaptability of legal systems to accommodate the complexities of modern society. In the context of Indian law, the recognition of deities as individuals with legal personality, akin to trusts and firms, has deep historical roots tracing back to British colonial rule. Landmark cases and legal precedents have affirmed the juridical status of deities, granting them rights and responsibilities within the legal framework. The role of representatives, such as the “next friend” or “friend of god,” has been pivotal in advocating for the interests of deities in court proceedings, as demonstrated in the Ayodhya title suit. Individuals like Deoki Nandan Agarwal, Thakur Prasad Verma, and Triloki Nath Pandey have played significant roles in representing the deity’s claims and advancing the legal battle over ownership disputes. Overall, the recognition of deities as juristic persons underscores the intersection of law, religion, and cultural heritage, shaping legal discourse and practice in India.

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