Author: Asmi Basu, JIS University
To the Point
Case Name: M. Siddiq (D) Thr. Lrs. v. Mahant Suresh Das & Ors.
Court: Supreme Court of India (5-judge Constitution Bench)
Bench Composition: Chief Justice Ranjan Gogoi, Justices S.A. Bobde, D.Y. Chandrachud, Ashok Bhushan, and S. Abdul Nazeer
Verdict Date: November 9, 2019
Disputed Property: 2.77 acres in Ayodhya (site of Babri Masjid, believed birthplace of Lord Rama)
Outcome: Full title awarded to Ram Lalla Virajman; 5‐acre alternative land allotted to Sunni Waqf Board
Abstract
The Ram Mandir case, formally titled M. Siddiq (D) Thr Lrs v. Mahant Suresh Das & Ors. , stands as a landmark in Indian legal history. This protracted dispute over a 2.77-acre plot in Ayodhya, believed by Hindus to be the birthplace of Lord Ram, juxtaposed religious sentiments with constitutional principles. The Supreme Court’s unanimous verdict in November 2019 sought to reconcile these facets, awarding the disputed land for the construction of a Ram temple while allocating an alternative site for a mosque. This ruling conclusively resolved a decades-long property dispute steeped in religious sentiment and legal complexity. The Supreme Court intricately balanced constitutional principles, property law, and historic and archaeological evidence. It recognized the deity as a juristic person for litigation, invalidated adverse possession claims by Muslims, and mandated formation of a temple trust while granting alternative land to Muslims—an outcome rooted in rule of law and aimed at social reconciliation. It analyzed legal principles—title suits, juristic personality of deities, adverse possession, limitation, res judicata—alongside historical, archaeological, and documentary evidence. We examine the Court’s reasoning, pivotal case laws, findings from ASI excavations, rationale for defeating adverse possession, and constitutional balance between secularism and religious freedom. The verdict mandated formation of a temple trust and equitable settlement, setting legal and societal precedents. This article delves into the legal intricacies, evidentiary assessments, and jurisprudential implications of the case.
Use of Legal Jargon
Title Suit: Determines legal ownership of immovable property
Juristic Person: Entities (e.g. deities) having legal rights and duties
Adverse Possession: Acquisition of title after open, hostile, exclusive possession for legally prescribed period
Res Judicata: Doctrine barring re-litigation of resolved disputes
Limitation Act (Section 65): 12-year deadline for adverse possession claims
Next Friend / Shebait: Representatives for minors or deities in litigation
Doctrine of Lost Grant: Presumption of original conveyance given continuous usage
Acquisition Act: Specific statute (Acquisition of Certain Areas at Ayodhya Act, 1993) affecting title clarity
The Proof
Archaeological Evidence (ASI Report, 2003)
Excavations indicated remnants of a non-Islamic superstructure (pillars, foundations) beneath the demolished mosque.
However, the Supreme Court noted the ASI didn’t ascertain whether a temple was demolished to build the mosque, only that there was an underlying structure.
Historical & Documentary Evidence
Colonial-era travelogues, inscriptions (e.g., ‘Vishnu Hari Shila Phalak’), and documents affirmed long-standing belief in Lord Rama’s birthplace at the site.
Diary entries and local records showed Hindu worship continued in the complex even under mosque governance.
The court acknowledged the deity, Ram Lalla Virajman, as a juristic person, thereby granting it the capacity to hold property and sue.
Possession & Title Records
Tax and revenue documents traced ‘Ram Chabutra’ and Ram Lalla’s presence as early as mid-20th century—aiding title claim.
The Waqf Board failed to prove continuous exclusive possession since construction in 1528; occupation lacked exclusivity, with Hindus entering outer courtyard areas.
Legal Issues & Court Reasoning
Juristic Personality of Deity
The deity was recognized as juristic person for purposes of property rights and litigation—but without conferring independent legal status on the land.
The Court treated Ram Lalla Virajman as a litigant via next friend representation, granting standing but not transferring legal identity to land.
Adverse Possession
To claim under Limitation Act Section 65, Waqf Board needed 12 years of hostile, exclusive, open, and uninterrupted possession.
The Court found possession was shared; frequent Hindu rituals inside disqualified exclusivity adverse possession claim failed.
Res Judicata & Limitation
Some defendants (e.g., Nirmohi Akhara) were time-barred or hit by res judicata due to prior judgments in multiple suits.
Courts noted that the deity’s suit (filed 1989) and Waqf suit (1961) exhaustively dealt with title issues—new forms of claims were blocked.
Allahabad High Court Verdict Overturned
The 2010 High Court verdict split land into equal shares—for deity, Waqf Board, and Nirmohi Akhara.
Supreme Court held partition was unsound, fragmented indivisible rights tied to place of worship; title must be determined before division.
Constitutional Principles & Secularism
Cited Ismail Faruqui v. Union of India (1994): worship in structures like mosques not essential; property is secular legal asset.
Court balanced Article 25–26 (religious freedom) with property law, avoiding state encroachment.
Acquisition Act’s Role
The Acquisition of Certain Areas at Ayodhya Act, 1993, made disputed land government-held Court ordered transfer via trust after creation.
Case Laws
Dr. M. Ismail Faruqui v. Union of India (1994): Mosque isn’t essential to Islam; secular legal principles apply.
Sheo Shankar v. Jaddo Kunwar (1897): Supports deity as juristic person.
Karnataka Waqf Board v. Govt. of India: Defines adverse possession requisites.
Ahmed Adam Sait v. Inayathullah: Represents limits of res judicata.
Conclusion
The Supreme Court’s decision in M. Siddiq epitomizes an evidence-based, legally consistent resolution to a historically charged dispute:
Evidence-led: Archaeological and documentary records fortified Hindu claims; Waqf Board lacked exclusive occupation.
Principled legal reasoning: Juristic personality, limitation, adverse possession, and constitutional rights were applied judiciously.
Equitable relief: Deity’s title recognized, alternate 5 acres allotted to Waqf Board; Nirmohi Akhara included in trust without proprietary rights.
Social harmony: Temple trust formation and mosque restitution were concrete steps toward communal reconciliation.
The Ram Mandir verdict reaffirms that India’s judicial system can resolve sensitive socio-religious disputes within constitutional boundaries—reflecting both faith and the rule of law.
FAQs
Q1: Why did the Court recognize Ram Lalla as a juristic person?
To allow the deity to hold title and litigate through a next friend, without granting autonomous legal status or fractional property rights.
Q2: What constitutes adverse possession, and why was it rejected?
Requires 12 years of hostile, exclusive, open, continuous possession—criteria the Waqf Board failed to prove. Shared access negated exclusivity.
Q3: What role did the ASI report play?
It revealed non-Islamic structures beneath the mosque, corroborating long-term Hindu claim—but stopped short of proving deliberate temple demolition.
Q4: Why didn’t the Court split the land?
Partition would disrupt the indivisible religious character of the site; title must vest wholly before division, not the other way.
Q5: What happened to the 5-acre alternative land for the mosque?
Government was directed to allot alternate land in Ayodhya to the Sunni Waqf Board for mosque construction—meant as restorative justice.
Q6: Are communal tensions resolved by this verdict?
While legally comprehensive, reconciliation lies in effective implementation of trust mandates and community goodwill—a work in progress.
Q7: What was the primary legal issue in the Ram Mandir case?
The central legal issue was the determination of title ownership over the disputed 2.77-acre land in Ayodhya, claimed by both Hindu and Muslim parties.
Q8: On what basis did the Supreme Court award the land for the Ram temple?
The court relied on archaeological evidence, historical records, and the legal recognition of the deity as a juristic person to conclude that the Hindu parties had established a better claim to the title.
Q9: What compensation was provided to the Muslim community?
The Supreme Court directed the government to allocate a separate 5-acre plot in Ayodhya for the construction of a mosque, ensuring restitution for the demolished Babri Masjid.
Q10: Has the construction of the Ram temple commenced?
Yes, following the verdict, the Shri Ram Janmabhoomi Teerth Kshetra trust was established to oversee the temple’s construction, which has been underway since the foundation stone was laid in August 2020.
