Author: Kunal Kumar, student at Soa National Institute of Law
Introduction
The Ram Janmabhoomi–Babri Masjid dispute stands as one of the most significant and sensitive legal battles in the history of independent India. At the heart of this dispute was a 2.77-acre piece of land in Ayodhya, Uttar Pradesh, which Hindus believe to be the birthplace of Lord Ram, and upon which stood the Babri Masjid, a mosque built in the 16th century by Mughal general Mir Baqi. This case brought forth complex questions involving religious belief, historical facts, property rights, and constitutional values.
After decades of legal battles, social unrest, and communal tensions, the matter was finally settled by the Supreme Court of India in November 2019, through the landmark judgment in M. Siddiq (D) Thr. Lrs. v. Mahant Suresh Das & Ors. The Court awarded the disputed land to the Hindu deity Ram Lalla Virajman, recognizing the deity as a legal person, and directed the government to allot 5 acres of alternate land to the Sunni Waqf Board for construction of a mosque.
This case is not only a turning point in Indian legal history but also an example of how the judiciary seeks to balance faith, law, and constitutional morality in a pluralistic democracy.
Historical Background and Facts of the Case
1. Ancient Belief and Hindu Faith:
In Hindu belief, Ayodhya is the place of birth of Lord Ram, one of the most sacred deities of Hinduism.
The believers are of the view that there was a Ram Temple here in ancient times.
The belief of “Ram Janmabhoomi” (birthplace of Ram) is centuries old and is deeply ingrained in the cultural and religious psyche of Hindus.
2. Babri Masjid Construction (1528):
In 1528, the mosque called Babri Masjid was constructed here by Mir Baqi, a Mughal general under Babur emperor.
It is claimed by most that the mosque was erected upon the destruction of an existing Hindu temple, though this is a subject of historical and archaeological dispute.
3. Early Conflicts (1853–1949)
1853: First documented communal conflicts were over the location.
1859: British government constructed a railing to divide Hindu and Muslim zones — Muslims prayed within the mosque, Hindus outside in the outer courtyard (Ram Chabutra).
1949: Idols of Lord Ram were installed within the mosque mysteriously. This resulted in legal and administrative conflicts. The area was shut by the government, and status quo was preserved.
4. Legal Proceedings Begin:
1950: Hindu devotees initiated civil suits to claim right to worship.
1959: Nirmohi Akhara initiated suit alleging rights to administer the temple.
1961: Sunni Waqf Board initiated suit for possession of the land and destruction of idols.
5. Babri Masjid demolition (1992):
On 6 December 1992, the Babri Masjid was destroyed by a mob of huge number of Hindu kar sevaks (volunteers) that resulted in violence and riots across the country.
This act was universally deplored and resulted in a number of criminal proceedings, as well as establishment of the Liberhan Commission to probe the incident.
6. Allahabad High Court Judgment (2010):
The Allahabad High Court gave a three-way division of the property:
1/3 to Ram Lalla Virajman
1/3 to Nirmohi Akhara
1/3 to Sunni Waqf Board
All sides appealed this judgment in the Supreme Court.
Supreme court’s Judgement and observation
Case Title: M. Siddiq (D) Thr. Lrs. V. Mahant Suresh Das & Ors.
Citation: (2019) 18 SCC 1
Date of Judgment: 9 November 2019
Bench: 5-Judge Constitutional Bench:- CJI Ranjan Gogoi, Justices S.A. Bobde, D.Y. Chandrachud, Ashok Bhushan, and S. Abdul Nazeer
# Final judgment of the Case
Whole Disputed Land Handed Over to Ram Lalla Virajman:
The whole 2.77-acre land was allotted to Ram Lalla Virajman (juristic person).
Central Government was ordered to create a Trust (“Shri Ram Janmbhoomi Teerth Kshetra”) within 3 months to administer the land and construct the temple.
2. 5 Acres of Alternative Land to Sunni Waqf Board:
As compensation, the Court ordered 5 acres of land to be given to the Sunni Waqf Board at a prominent site in Ayodhya to build a mosque.
3. Nirmohi Akhara’s Suit Rejected:
The suit of Nirmohi Akhara as a shebait (trustee of the deity’s property) was rejected as time-barred.
# key observation of Supreme Court
1. Dharma vs. Kanoon
“The Court should not rule by faith or belief but by evidence and principles of law.”
The Court acknowledged the religious belief of Hindus in Ram Janmabhoomi.
However, it made clear that belief per se cannot establish legal title—evidence is necessary.
2. Illegal Acts Condemned:
“The destruction of the Babri Masjid in 1992 was a blatant disregard of the rule of law.”
The Court denounced the 1992 destruction of the Babri Masjid as illegal.
It reiterated that the wrongs done must not find justification through law.
3. Possession and Usage;
The Hindu sides established a continuous pattern of use and presence in the outer courtyard (Ram Chabutra).
Muslims did not succeed in establishing exclusive possession of the inner courtyard before 1857.
4. Archaeological Evidence (ASI Report):
ASI report reinforced the fact that a non-Islamic structure existed under the mosque.
But the Court made it clear that the presence of such a structure is not irrefutable evidence of demolition of a temple by Muslims.
5. Deity as a Legal Person:
The Court reaffirmed the status of Hindu deity (Ram Lalla) as a juristic person, having the capacity to own property and sue in its own name.
6. Secularism and Equality:
The verdict promoted the secular nature of the Constitution.
It vested equal respect in every religion and tried to give balanced justice to both communities.
📝 Legal and Constitutional Provisions involved….
1. Article 25 & Article 26 of Indian Constitution
Article 25: Ensures the freedom of religion to all individuals.
Article 26: Provides religious denominations with the right to administer their own religious affairs.
Court’s Perspective:
The Court recognized that Hindus and Muslims alike have religious rights under these articles. But these rights are dependent on public order, morality, and health, and not upon private property or the rule of law.
2. Indian Evidence Act, 1872
Regulates the admission and assessment of evidence in courts.
Application:
The Court had recourse to oral evidence, documentary evidence, archaeological evidence, and historical evidence. It emphasized title or ownership cannot be determined by faith; it has to be established on legal evidence.
3. Civil Procedure Code, 1908 (CPC)
Especially Order 7 Rule 11 – Rejection of plaints (employed during rejecting certain claims).
Rules pertaining to civil suits, partition, limitation, and maintainability of suits.
Application:
The Court analyzed several suits instituted by Hindu and Muslim parties based on CPC concepts such as limitation, cause of action, res judicata, etc. Nirmohi Akhara’s suit was rejected as time-barred under the Limitation Act.
4. Limitation Act, 1963
Imposes time limits for which legal proceedings must be instituted.
Application:
The Court dismissed arguments filed outside the legal time period (e.g., Nirmohi Akhara’s argument as shebait was dismissed as being barred by limitation).
5. Juristic Personhood Recognition:
Indian law permits some entities (such as idols, temples, trusts) to be regarded as legal persons.
Application:
The deity “Ram Lalla Virajman” was accepted as a juristic person who can own property and sue by a next friend. The Court recognized that Hindu law identifies idols as living beings in law.
6. Principle of Restitution:
Where a party is injured by an illegal act, the court can restore their rights or give compensation.
Application:
The Court ruled the demolition of Babri Masjid in 1992 illegal, and thus directed 5 acres of land to be given to the Sunni Waqf Board as relief.
7. Archaeological Evidence:
Although not a law in itself, the ASI Report was taken as expert testimony under the Evidence Act.
Application:
The Court took into account ASI observations that there was a non-Islamic building underneath the Babri Masjid. It was, however, cautious in holding there was no conclusive evidence of destruction of a temple.
📝 Conclusion
The Ram Janmabhoomi&Babri Masjid case is one of India’s most important and sensitive legal cases. The 2019 judgment by the Supreme Court balanced and lawful outcome by recognizing the religious beliefs of crores while firmly basing its ruling upon constitutional values and judicial evidence. By bestowing the land in dispute to Ram Lalla Virajman and providing substitute land for the Sunni Waqf Board, the Court asserted justice, equality, and national harmony.
This judgment is not merely a judicial decision—it is a message that rule of law, secularism, and peaceful coexistence have to triumph in a democratic and multicultural society such as India.
FAQS
About what Ram Janmabhoomi–Babri Masjid dispute was it?
It was a dispute over land about the area in Ayodhya which Hindus claimed as the birthplace of Lord Ram and Muslims as the place of Babri Masjid.
What did the Supreme Court rule in 2019?
The Court awarded the whole disputed land to Ram Lalla and gave 5 acres to the Sunni Waqf Board for a mosque.
Who was the main petitioner in the Supreme Court?
The chief petitioner was M. Siddiq, on behalf of the Sunni Waqf Board.
What did the Court use as evidence?
The Court used archaeological reports, historical documents, and legal ownership, not religion.
What is the importance of the judgment?
It resolved a long-standing controversy and strengthened secularism, rule of law, and peaceful resolution.
