“No game of hide and seek”: the Madras High Court has held that FCRA Registration was rightly refused to a Kodaikanal Zen meditation trust, since an applicant under the Foreign Contribution (Regulation) Act must correctly disclose its religious character.
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Madurai: The Madurai Bench of the Madras High Court has dismissed an appeal by Kanzeon Public Charitable Trust, which runs a Zen meditation centre in Kodaikanal, against the Centre’s refusal to register it under the Foreign Contribution (Regulation) Act, 2010 (FCRA). The Court held that the Trust presented itself as a non-religious body although, on its own showing, it is a religious organisation [Kanzeon Public Charitable Trust v. Union of India].
Justice G.R. Swaminathan and Justice M.D. Sumathi formed the Division Bench, which reserved judgment on October 1 and pronounced it on October 6, 2026. G. Baskar argued for the Trust, and G. Thalaimutharasu, Senior Standing Counsel, for the Union of India.
Candour was the sticking point
The Bench looked first at the application form prescribed under the FCRA Rules, which asks applicants to say whether they are religious, cultural, economic, educational or social organisations. The Trust claims to follow Zen Buddhist philosophy, and the Court held that it is, on its own showing, a religious organisation. Nothing in the Act, it added, bars such an organisation from applying.
What went wrong, according to the Court, was the manner of applying. An applicant, it said, “has to make a clean breast of everything”, and it was “no game of hide and seek”. An application must correctly disclose the nature of the applicant, the Court held, and failing to do so will lead to rejection.
The Trust and its appeal
Set up in 2021, the Trust runs a Zen meditation centre in Kodaikanal and already enjoyed tax exemption. The Deputy Director (FCRA) rejected its application for FCRA registration, relying on the conversion-related ground in Section 12(4)(a)(ii) of the Act. In its appeal to the High Court under Section 31, the Trust contended that practising meditation does not make it a religious organisation. While describing the Trust’s background, the Court noted that its founder is an ordained Christian priest.
The Bench’s remarks on religions
In explaining why conversion concerns arise under the Act, the Bench made general observations on religious traditions and tied them to the law’s secular purpose:
“Unlike Hinduism which is inclusive, the Abrahamic religions are inherently exclusive.”
It was just as categorical about the other side of the line, and it clarified its position on the Trust:
“A fundamentalist Hindu Organisation engaged in Ghar Wapsi cannot be registered under FCRA. The statutory regime which was put in place during UPA rule (2010) is intended to subserve secular objects. We hasten to clarify that we do not accuse the appellant of having any such agenda.”
India is a pluralist nation, the Bench said, a “salad bowl” rather than a melting pot, and religious organisations whose activities do not affect the nation’s secular fabric and social amity are entitled to FCRA registration.
Guidance for other organisations
On the classification question, the Court also offered guidance to others. An organisation whose main work is the systematic teaching of Indian Knowledge Systems such as Vedanta, the Bhagavad Gita, the Upanishads or Yoga should ordinarily be treated as educational or cultural, not religious. The Bench linked this to the National Education Policy 2020.
Outcome
The rejection order must stand, the Court concluded, as the authority’s discretion is open to judicial review only on limited grounds.
“For the foregoing reasons, the order impugned in this civil miscellaneous appeal is sustained. This appeal is dismissed.”
No costs were awarded.
Why the judgment matters
The ratio is narrow and practical. An organisation seeking FCRA registration must describe itself accurately on the form, and being religious is not by itself a bar. Those unsure whether their work counts as religious, educational or cultural will find the Court’s guidance on Indian Knowledge Systems useful.
The Bench’s general remarks on religious traditions came in the course of that reasoning, and they sit alongside its clarification that it was not accusing the Trust of any conversion agenda.
Case Title: Kanzeon Public Charitable Trust v. Union of India [CMA(MD) No. 1057 of 2026]
Bench: Justice G.R. Swaminathan and Justice M.D. Sumathi, Madras High Court (Madurai Bench)
Date of Judgment: October 6, 2026
Appearances: G. Baskar (Appellant); G. Thalaimutharasu, Senior Standing Counsel (Union of India)