Case Summary: M. Siddiq (D) Thr. LRs v. Mahant Suresh Das & Ors. 2019

Case Title: Siddiq through Legal Representatives v. Mahant Suresh Das & Others.

Case Citation: 2019 SCC OnLine SC 1440, (2020) 1 SCC 1

Date of judgment: Nov 9 2019

Court & Bench: Supreme Court of India, five-judge Constitution Bench- Ranjan Gogoi, (CJI) S.A. Bobde, D.Y. Chandrachud, Ashok Bhushan, S. Abdul Nazeer, JJ.

Appeal From: Allahabad High Court, Lucknow Bench, judgment dated 30 Sept. 2010 (three-way partition of the site).
Jurisdiction: Civil appellate jurisdiction in appeals from four title suits tried together. The judgment was unanimous and authored in a single voice.

Factual Background

The dispute concerns ownership of a 0.313-acre inner courtyard within a 2.77-acre precinct in Ayodhya, revered by Hindus as Lord Ram’s birthplace. A mosque, the Babri Masjid, stood there from the 16th century until its demolition on 6 December 1992. British-era records showed Hindus worshipping in the outer courtyard while Muslims offered namaz inside the mosque.

Key flashpoints were the 1934 communal damage to the mosque, the secret placing of idols under the central dome in December 1949, and the mosque’s demolition in 1992. Following the 1949 event, Muslims were barred from worship inside the inner courtyard. Multiple suits were filed by Hindu devotees (1950), the Nirmohi Akhara, and the Sunni Central Waqf Board, with Ram Lalla Virajman added in 1989.

In 2010, the Allahabad High Court ordered a three-way division among Ram Lalla, the Akhara, and the Waqf Board.

Issues

1) Whose claim to title/possession over the disputed inner courtyard was superior on a balance of probabilities Ram Lalla Virajman (Suit 5) or the Sunni Waqf Board (Suit 4)?

2) Whether Nirmohi Akhara was the shebait of the deity and whether its suit was within limitation.

3) What weight should be accorded to the ASI’s 2003 excavation report showing a large, non-Islamic structure predating the mosque?

4) What is the legal significance of the 1949 desecration and the 1992 demolition?

5) How do the Places of Worship Act, 1991, and the Acquisition of Certain Area at Ayodhya Act, 1993, interact with the dispute, and what relief can be moulded under Article 142 of the Constitution?

Arguments 

Hindu parties claimed long-standing worship, access to the inner court before 1949, and relied on the ASI report to argue the mosque stood on a prior Hindu temple. They invoked the deity’s juristic status and sought exclusive title, rejecting the High Court’s partition. Muslim parties maintained the Babri Masjid functioned until 1949, stressed that faith cannot replace legal title, and called the ASI report inconclusive. They argued any prior structure could not legally displace the mosque and opposed validating worship patterns shaped by the unlawful 1949 and 1992 events.
Evidence Considered

The Court assessed revenue records (khasras, khataunis), travellers’ accounts, gazetteers, FIRs and administrative orders from 1949, oral testimony, and expert material. It treated the ASI report as corroborative rather than conclusive: the excavations revealed pillar bases and architectural remnants inconsistent with an Islamic origin, suggesting a substantial pre-existing Hindu religious structure beneath the mosque. The Court also weighed evidence showing continuous Hindu worship in the outer courtyard and patterns of Hindu presence within the inner precinct prior to 1949 against evidence that Muslims performed namaz there at least until the late 1940s, though with increasing obstruction.

Legal Principles Applied

The Court said that Ram Lalla (the deity) is treated as a legal person under law (based on earlier cases like Deoki Nandan v. Murlidhar, 1957), so he can own land and sue, but the land itself (janmabhoomi) is not a legal person.

In civil law, proof is judged on the “preponderance of probabilities”. Based on this, the Hindu side’s evidence of long worship and possession was found stronger than the Muslim claim of exclusive possession until 1949.

The Nirmohi Akhara’s case was dismissed as time-barred under the Limitation Act, 1963, while the Sunni Waqf Board’s case, though valid under the Waqf Act, 1995 failed against the deity’s stronger claim.

The Court ruled the 1949 idol placement and the 1992 demolition unlawful, but under law these acts did not themselves decide ownership; they only shaped the fair relief to be given. The Places of Worship (Special Provisions) Act, 1991 did not apply to Ayodhya because its Section 5 specifically excluded it.

The Acquisition of Certain Areas at Ayodhya Act, 1993 gave the Union Government power to take over the land and create a trust for its management. Finally, the Court relied on Article 142 of the Constitution of India to do “complete justice” and deliver a final, workable solution.

Decision and Ratio Decidendi

The Supreme Court unanimously decreed Suit 5 (Ram Lalla Virajman) and set aside the High Court’s partition. On the evidentiary record, the Hindu parties established a superior possessory/title claim to the composite site. The ASI report made it unlikely that the mosque was built on vacant land and was read consistently with other materials indicating a large, non-Islamic antecedent structure.

Exercising Article 142, the Court directed the Union Government to create a trust and vest the entire 2.77 acres in it for the construction of a temple, and directed the State of Uttar Pradesh to allot a prominent 5-acre plot within Ayodhya to the Sunni Central Waqf Board for a mosque. The Court also recorded that Nirmohi Akhara could be given appropriate representation in the trust to be constituted.

Reliefs and Directions

• Entire disputed land to vest in a central government–constituted trust; possession to remain with the statutory receiver until vesting.
• Uttar Pradesh to allot 5 acres in Ayodhya city to the Sunni Waqf Board for a mosque.
• High Court’s three-way partition set aside; Akhara’s suit dismissed as time-barred; liberty for Akhara to seek representation in the trust.

Analysis and Commentary

The Court decided the case as a normal land dispute, not on the basis of faith. It said proof must follow civil law standards. The ASI report was treated as supporting evidence, not final proof, but with records and long worship practices, the Hindu claim was found stronger. At the same time, the Court clearly said the 1949 idol placement and the 1992 demolition were illegal. Still, giving the whole site to the Hindu side, despite those wrong acts, raised questions. To balance this, the Court used Article 142 of the Constitution to give Muslims 5 acres elsewhere.

The Court clarified that the deity (Ram Lalla) is a legal person, not the land itself, and that land disputes can’t be split without a legal basis. It also said archaeology alone can’t decide the title; it must be read with other evidence. By giving one unanimous judgment, the Court showed unity and avoided reopening earlier debates on the role of mosques in religion. In the bigger picture, the ruling shaped the law on religious trusts, highlighted the Places of Worship Act, 1991 as protection for other sites, and left a mixed legacy some saw closure, others felt hurt.

Impact and Subsequent Developments 

Following the Court’s order, the Union Government set up the Shri Ram Janmabhoomi Teerth Kshetra Trust in 2020 under the 1993 Act and handed the site to it. The trust is building the Ram temple, whose sanctum was consecrated in January 2024. The State gave the Sunni Waqf Board 5 acres in Dhannipur for a new mosque. Review and curative petitions failed, so the verdict stands.

As precedent, it guides future cases on religious endowments, use of archaeology, and fair remedies. The judgment made clear:

1. Old historical wrongs cannot be fixed through land suits.
2. Archaeological findings are only supporting evidence, not final proof.
3. Article 142 can balance fairness without changing the main title decision.

Key Takeaways

• The Court treated the case as a normal land/title dispute, not a matter of faith or theology.
•  It held that the deity Ram Lalla is a legal person who can own property, but the land (janmabhoomi) itself is not a legal person.
• The ASI report was seen only as supporting evidence of a pre-existing non-Islamic structure; it could not by itself prove ownership.
• The placing of idols in 1949 and the demolition of the mosque in 1992 were both declared illegal acts.
• Still, the Court gave the disputed land to the deity’s side, but used Article 142 of the Constitution to balance fairness by giving the Waqf Board 5 acres at Dhannipur for a mosque.
• The Allahabad High Court’s 3-way partition of the land was set aside because partition is not proper in title suits.
• The Sunni Waqf Board’s case was legally valid but failed against the stronger claim of the deity.
• The Court stressed that archaeological findings must be read with other evidence like worship practices and records, not in isolation.
• It also underlined that old historical wrongs cannot be corrected through courts in land disputes.
• The judgment showed a unanimous decision by all judges, which gave the case a sense of finality.
• It also confirmed that the Places of Worship Act, 1991 protects other sites from similar disputes, making Ayodhya a special exception.

References:

1. M. Siddiq (D) Thr. LRs v. Mahant Suresh Das, 2019 SCC OnLine SC 1440; (2020) 1 SCC 1 (India).
2. Judgment Summary, M. Siddiq (D) Thr. LRs v. Mahant Suresh Das (Ayodhya Title Dispute), Supreme Court Observer, https://www.scobserver.in (last visited Aug. 23, 2025).
3. The Places of Worship (Special Provisions) Act, No. 42 of 1991, 5 (India).
4. The Acquisition of Certain Areas at Ayodhya Act, No. 33 of 1993, 6–7 (India).
5. Deoki Nandan v. Murlidhar, AIR 1957 SC 133 (India).
6. Allahabad High Court (Lucknow Bench), M. Siddiq (D) Thr. LRs v. Mahant Suresh Das & Ors., judgment dated Sept. 30, 2010.
7. Archaeological Survey of India, Excavation Report (Ayodhya, 2003), as discussed in the Supreme Court’s judgment (2019).
8. ‘SC invoked Article 142 to order formation of trust for Ram Mandir,’ The Print (Nov. 9, 2019), https://theprint.in (last visited Aug. 25, 2025).