Shiromani Gurdwara Prabandhak Committee v. Som Nath Dass (2000) 4 SCC 146
Supreme Court of India 2000 Bench: SC Citation: (2000) 4 SCC 146 Area: Religious Endowments & Property Read: ~7 min
Gulzar Hashmi
India
31 Oct 2025
shiromani-gurdwara-prabandhak-committee-v-som-nath-dass-2000-4-scc-146
CASE_TITLE: Shiromani Gurdwara Prabandhak Committee v. Som Nath Dass (2000) 4 SCC 146
PRIMARY_KEYWORDS: Guru Granth Sahib juristic person, gurdwara property, Sikh Gurdwara Act 1925
SECONDARY_KEYWORDS: religious endowment, SGPC, charitable trust, locus standi, Tribunal
PUBLISH_DATE: 31-10-2025
AUTHOR_NAME: Gulzar Hashmi
LOCATION: India
Quick Summary
- Core The Court held that Guru Granth Sahib is a juristic person capable of holding property.
- Integration The gurdwara and Guru Granth Sahib are one integrated juristic entity.
- Result Tribunal’s decision in favor of SGPC was restored; High Court was overturned.
Issues
- Can the Guru Granth Sahib be treated as a juristic person capable of owning property?
- Do endowments for religious/charitable purposes create juristic entities in law?
- Who can act on behalf of such a juristic entity?
Rules
- Religious/charitable endowments recognized by society can create a juristic person (idol, mosque, church, gurdwara’s central object of worship).
- Under the Sikh Gurdwaras Act, 1925, the central body of worship in a gurdwara is the Guru Granth Sahib.
- The gurdwara and the Guru Granth Sahib are not separate legal persons; they form one integrated whole.
Facts — Timeline
Petition u/s 7(1): ~56 villagers seek declaration that the disputed property is a Sikh gurdwara; boundaries notified in Gazette.
Composite objection (ss. 8 & 10): Som Dass & others claim it is a Dharamshala/dera of Udasins, owned/managed by them for generations.
Before Tribunal: SGPC says it is a Sikh gurdwara; Guru Granth Sahib is the only object of worship and owner of property; also challenges objectors’ locus under s.8.
Tribunal outcomes: s.8 objection rejected; on s.10, Tribunal holds land/buildings belong to Gurdwara Sahib Dharamshala Guru Granth Sahib; respondents were only managers.
High Court appeal: Respondents argue entries in revenue records in name of Guru Granth Sahib are void since it is not juristic; High Court agrees.
Supreme Court: Reverses High Court; affirms Tribunal and recognizes juristic personality of Guru Granth Sahib.
Arguments
Appellant: SGPC
- Disputed place is a Sikh gurdwara; Guru Granth Sahib is central object of worship and juristic owner.
- Endowment recognized by the community → juristic person in law.
- Respondents lacked locus standi under s.8; they were only managers, not owners.
Respondents
- Place is a Dharamshala/dera of Udasins, owned/managed by them historically.
- Guru Granth Sahib cannot be a juristic person; revenue entries invalid.
- Property should not vest in SGPC; Tribunal erred.
Judgment
- Guru Granth Sahib is a juristic person capable of holding property.
- Gurdwara + Guru Granth Sahib together form one integrated juristic entity.
- A juristic religious entity may act via trustees/managers/courts as permitted by law.
- Appeal allowed; High Court judgment set aside; Tribunal decision for SGPC affirmed.
Ratio Decidendi
Where a religious endowment is recognized by society, the central object of worship can attain juristic personality. In a gurdwara, the Guru Granth Sahib is that central body of worship; hence, it is a juristic person and the gurdwara is not separate from it.
Why It Matters
- Clarifies legal personality of sacred texts/objects in Indian law.
- Helps resolve title and management disputes over religious properties.
- Guides how trustees and managers can act for such entities.
Key Takeaways
Guru Granth Sahib = Juristic person.
Gurdwara & scripture form one entity.
Religious endowment + social recognition → legal personality.
Acts through trustees/managers/courts.
Mnemonic + 3-Step Hook
Mnemonic: E-R-I — Endowment → Recognition → Integrated juristic person.
- Endowment exists for worship/charity.
- Recognition by community and law.
- Integration of gurdwara & Guru Granth Sahib as one legal person.
IRAC Outline
| Issue | Rule | Application | Conclusion |
|---|---|---|---|
| Whether Guru Granth Sahib can be a juristic person owning property. | Endowments recognized by society create juristic persons; Sikh Gurdwaras Act identifies Guru Granth Sahib as central worship. | Community practice + statutory context show juristic personality; management acts via trustees/courts. | Guru Granth Sahib is a juristic person; gurdwara is not a separate entity; SGPC’s claim succeeds. |
Glossary
- Juristic Person
- A non-human entity recognized by law as having rights and duties (e.g., idol, trust, company).
- Endowment
- Property dedicated to a religious/charitable purpose to be used only for that purpose.
- Locus Standi
- Legal capacity to bring a challenge or be heard in a matter.
FAQs
Yes, if a recognized religious endowment and social practice support it. Here, the Guru Granth Sahib qualifies.
Through trustees/managers under law and oversight of courts if needed.
Yes. The Supreme Court restored the Tribunal decision in SGPC’s favor and set aside the High Court’s view.
No. They are treated as one integrated juristic entity for ownership and legal status.
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