·
Board
questions validity of 1951 long-term lease; directs Jatni Tahasildar to correct
Record of Rights (RoR).
·
Revenue
Department reiterates commitment to protecting Lord Jagannath’s landed
properties across Odisha.
THEBUSINESSBYTES
BUREAU
BHUBANESWAR,
JULY 10, 2026
In a landmark ruling
in the long-pending dispute over land belonging to the Ekharajat Mahal of Lord
Jagannath, the Court of the Member, Board of Revenue, has ordered restoration
of the disputed property to Shri Jagannath Mahaprabhu Bije, Puri. The 33-page
judgment, delivered after an expedited hearing by Satyabrata Sahu, Member,
Board of Revenue, allowed two revision petitions and directed the Tahasildar,
Jatni, to correct the current Record of Rights (RoR) by recording the land in
the name of Shri Jagannath Mahaprabhu Bije, Puri, represented through the Shri
Jagannath Temple Managing Committee.
The dispute relates
to a substantial parcel of land located in Kudiyari Mouza under Jatni Tahasil
in Khordha district. The Temple authorities challenged the validity of a
long-term lease granted in 1951 for setting up an industrial unit, contending
that the lease was not legally sustainable. Based on that lease, the land had
subsequently been recorded in the current RoR in the names of private individuals,
including Nilamani Dubey and others, as well as Gopabandhu Glass & Pottery
Works Ltd.
In its judgment, the
Court held that under Section 58 of the Orissa Hindu Religious Endowments Act,
1939, any lease of immovable property belonging to a religious institution for
a period exceeding five years required prior approval of the Commissioner of
Endowments. The Court observed that the opposite parties failed to produce any
evidence showing that such mandatory approval had been obtained. It further
clarified that mere registration of a lease deed does not, by itself, validate
a transaction that is otherwise contrary to law.
The Court also noted
that although the lease was granted for establishing an industrial unit, no
material was placed on record to demonstrate that any such unit had ever been
established or that the Temple had derived any financial benefit from the
lease. On the contrary, the latest field inspection report submitted by the
Tahasildar revealed that the disputed land continues to remain vacant.
Reiterating settled
legal principles, the Court held that a Record of Rights does not confer
ownership but serves only as prima facie evidence of possession. It observed
that where an RoR entry is founded on an illegal transaction, the revisional
authority has full jurisdiction to correct the record.
The judgment also
referred to the Supreme Court's ruling in the Shri Jagannath Temple Managing
Committee vs. Siddha Math case, reaffirming that statutory safeguards enacted
for the protection of temple properties must prevail and that no legal rights
can accrue in violation of those provisions.
After examining the
entire record, the Court concluded that the current RoR prepared in 1965
suffered from legal infirmities and could not be sustained. It accordingly
directed the Tahasildar, Jatni, to immediately correct the RoR by recording the
disputed land in the name of Shri Jagannath Mahaprabhu Bije, Puri, represented
through the Shri Jagannath Temple Managing Committee, under the classification
"Anabadi–Puratana Patita" (Old Fallow Land).
Legal experts believe
the verdict is likely to become a significant precedent in disputes involving
the protection of properties belonging to temples and other religious
institutions. The judgment also reinforces the State Government's ongoing
efforts to safeguard the immovable properties of Lord Jagannath across Odisha.
The Revenue & Disaster Management Department has constituted a dedicated Shri Jagannath Mahaprabhu Land Cell to ensure the protection, preservation and effective management of all landed properties recorded in the name of Lord Jagannath.
Welcoming the judgment, senior advocate Ambika Prasad Mishra, who represented Shri Jagannath Mahaprabhu Bije, Puri through the Shri Jagannath Temple Managing Committee, described the verdict as a major step towards protecting the deity's properties. He reiterated that the Temple Administration would continue to pursue all necessary legal and administrative measures to restore and safeguard Lord Jagannath's landed assets. The judgment has also been widely welcomed by devotees and admirers of Lord Jagannath across the State.
