Daily rituals and festivals stay with the Podhu Dikshitars; property, accounts, heritage conservation and public access do not. In a sweeping ruling on Chidambaram Nataraja Temple Administration, the Madras High Court has placed the ancient Sri Sabanayagar Temple under a five-member Board of Management headed by two retired High Court judges.
Chennai: “Till the ill is cured”: on those terms, the Madras High Court on Friday (October 30) constituted a Board of Management of domain experts to take over the administration of the Chidambaram Nataraja Temple, holding that the temple’s heritage structures had been damaged and its properties left unaccounted for under the management of the Podhu Dikshitars [Sri Sabanayagar Temple v. State of Tamil Nadu and Others].
The judgment came from a Division Bench of Dr. Justice G. Jayachandran and Justice E. Manoharan on a batch of writ petitions, including one filed by the temple itself through the Secretary of the Podhu Dikshitars, T.S. Sivarama Dikshitar. The Bench had reserved its verdict on October 12.
Rituals and festivals remain with the Dikshitars
“In respect of daily rituals and periodical festivals, it is the exclusive prerogative of the Podhu Dikshitars and same to be conducted without violating the established customs and practices.”
Fixed deposits and other temple income so far handled by the Dikshitars will remain with them, but their Secretary must submit a copy of the accounts to the Board by the 5th of every month. The Special Tahsildar (Property) will continue to collect rents and Kattalai dues under the Board’s supervision. All donations must henceforth be made through a single-window e-payment into an account named by the Board, and donations earmarked for a particular renovation must be kept and spent for that purpose.
Who sits on the Board, and what it must do
“Therefore, we constitute a Board of Management consisting of domain experts, who will take over the administration, till the ill is cured.”
The Board will be chaired by Justice V. Bharathidasan (Retd.), with Justice R. Suresh Kumar (Retd.) as Co-Chairman and C. Rajendran, IAS (Retd.), as Member. The Secretary of the Podhu Dikshitars and the Secretary to the Government, HR&CE Department, will serve as ex-officio members.
The Board has been directed to:
- ensure, in consultation with the Podhu Dikshitars, fair and equal opportunity for the public to have darshan at the Kanagasabai by climbing atop, without violating customary practices;
- remove unauthorised or unnecessary constructions inside the temple in consultation with the Tamil Nadu Heritage Commission;
- retrieve encroached temple properties with the help of the District Administration and recover rental and lease arrears;
- augment income from temple properties and maintain proper accounts;
- renovate the temple, including its consecration, without altering the ancient heritage structure; and
- take inventory of movables and valuables and secure any that are missing.
The three non-ex-officio members will receive a remuneration of Rs 2 lakh a month each, with a car, driver and round-the-clock personal security in the rank of Inspector of Police. The Board’s expenses will be met from HR&CE Department funds, and Rs 10 lakh is to be vested with it for contingencies. The Chief Secretary of Tamil Nadu must ensure facilities and cooperation, and the Revenue and Public Works Departments must assist the Board.
The findings behind the Board
The Bench framed three questions. It held that G.O.Ms. No. 115 was not a colourable exercise of executive power meant to override the denominational rights of the Podhu Dikshitars. It found that the heritage structure of the temple had been damaged under their management in the guise of renovation and maintenance. And it held that the temple’s movable and immovable properties had not been properly accounted for or audited.
Recalling the Supreme Court’s 2014 ruling, the Bench noted the limits on State interference with a denomination’s administration:
“The right of the religious denomination to administer its property can be interfered only on the ground of maladministration and that to only until the evil gets remedied. Any perpetual supervision would be violative of Article 26(d) of the Constitution of India.”
The Court then recorded its finding on the period after that judgment:
“For more than 12 years the entire income of the temple is with the Podhu Dikshitars but they are not ready to share the true and full account of the income derived from the temple. Therefore, we have no hesitation to record that the manner in which the ancient structure of the temple has been damaged and ill-maintained under the management of the Podhu Dikshitars is disheartening.”
The Bench also found no plausible explanation for constructions made inside the temple that damaged sculptures and murals. It referred to hand bills in the name of the Dikshitars inviting donations for Annadhanam with the menu listed, and to the use of the dining hall inside the temple for events, observing that such non-religious and commercial activities had converted the temple premises into a “food court”. It added that the accounts of temple income and expenditure required forensic auditing.
G.O.Ms. No. 115 and the petitions
The petitions arose from G.O.Ms. No. 115 dated May 17, 2022, by which the Tamil Nadu government permitted devotees to climb the Kanagasabai Mandapam for darshan of Lord Nataraja. Apart from the temple’s petition (W.P. No. 36022 of 2023), the batch included writ petitions filed by T.R. Ramesh (W.P. No. 20467 of 2023) and K. Rajasekhar (W.P. No. 30365 of 2023), along with several miscellaneous petitions.
The Podhu Dikshitars argued that the government order interfered with their right under Article 26 of the Constitution, as a religious denomination, to administer the temple’s religious affairs. They relied on the Supreme Court’s 2014 judgment in Dr. Subramanian Swamy v. State of Tamil Nadu, which had returned the administration of the temple to them. The State and the Hindu Religious and Charitable Endowments (HR&CE) Department defended the order.
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Expressing the hope that the Board would “take the charge forthwith and bring back the glory of the temple at the earliest”, the Bench disposed of the writ petitions without costs.
What the ruling signals
The Chidambaram temple has been at the centre of a long contest between the Podhu Dikshitars and the State. In 2014 the Supreme Court held that a denomination’s right to administer its institution under Article 26(d) cannot be displaced permanently, and that the State may step in only for maladministration and only until it is remedied. This judgment works within that framework: it does not hand the temple to an HR&CE Executive Officer, but to a court-constituted board, and expressly ties its tenure to the cure of the maladministration it found.
The ruling also draws a line between the religious and the secular. Rituals, festivals and customs remain the exclusive domain of the Dikshitars, while property, accounts, heritage conservation and public access move to independent supervision. How that division works in practice, and whether the judgment is carried further on appeal, will shape the governance of one of Tamil Nadu’s most revered temples.
Case Title: Sri Sabanayagar Temple, represented by the Secretary, Podhu Dikshitars v. State of Tamil Nadu and Others [W.P. Nos. 36022, 20467 and 30365 of 2023; 2026:MHC:4389]
Bench: Dr. Justice G. Jayachandran and Justice E. Manoharan, Madras High Court
Reserved on: October 12, 2026
Date of Judgment: October 30, 2026
Appearances: Advocate K. Harishankar for the Podhu Dikshitars; Special Government Pleader R. Bharanidharan for the State and the HR&CE Department; Advocate Naveen Aravindhan for another petitioner