A Peaceful Resolution: Supreme Court Settles Jain Temple Dispute Through Mediation

Court: Supreme Court of India.

Case Name: Shri Jain Shwetamber Shri Sangh Panjikrit Sanstha vs. State of Rajasthan

Citation: 2025 INSC 41. [PDF]

Introduction

The Supreme Court of India addressed a long-standing property dispute between two Jain religious organizations, Shri Jain Shwetamber Shri Sangh Panjikrit Sanstha and Shri Jain Shwetamber Khartargachh Sangh. The dispute concerned the ownership and management rights of specific properties, notably a "Dadabari complex" and two temples in Ajmer.

The case had a complex history, beginning with a Civil Suit at the Trial Court level in 2017, followed by appeals to the Rajasthan High Court, and finally reaching the Supreme Court through a Special Leave Petition. The matter was initially decided by the Trial Court in Civil Suit No. 22 of 2017. The Rajasthan High Court dismissed an appeal against the Trial Court's decision.

Instead of proceeding with further litigation, the Supreme Court, with the consent of both parties, employed an alternative dispute resolution method. The court referred the matter to mediation, and appointed a former Judge of the Supreme Court, Hon’ble Mr. Justice S. Ravindra Bhat (Retd.), as the mediator. This decision highlights the court's willingness to use mediation to resolve complex disputes, particularly those involving religious entities.

Case Summary

  1. The dispute originated from a Civil Suit (No. 22 of 2017) at the Trial Court level, which was appealed to the Rajasthan High Court (S.B. Civil First Appeal No.1015 of 2019), and then to the Supreme Court via a Special Leave Petition (S.L.P. (C) No.25759 of 2023).
  2. The core issue involved the ownership and management rights of the Dadabari complex and two temples in Ajmer.
  3. The Supreme Court, with consent from both parties, referred the matter to mediation on December 1, 2023, appointing Hon’ble Mr. Justice S. Ravindra Bhat (Retd.) as the mediator.
  4. A Compromise Agreement was signed by both parties on December 7, 2024, outlining the settlement terms.
  5. As per the settlement, the Dadabari complex was assigned to the sole ownership, possession, and management of Shri Jain Shwetambar Khartargachh Sangh.
  6. Shri Jain Shwetamber Shree Sangh was granted exclusive ownership and management rights over two temples in Ajmer: Sambhavnath Bhagwan ka Mandir and Rishabhdev Bhagwan ka Mandir.
  7. Shri Jain Shwetamber Shree Sangh retained sole rights to operate and withdraw funds from three specified bank accounts at Punjab National Bank, Vaishali Nagar, Ajmer.
  8. Shri Jain Shwetambar Khartargachh Sangh agreed to pay ₹8,11,00,000 to Shri Jain Shwetamber Shree Sangh.
    • ₹11,00,000 was paid upon execution of the agreement.
    • The remaining ₹8,00,00,000 was paid when the Supreme Court passed the final order.
  9. All pending cases between the two parties in various courts were to be withdrawn and closed.
  10. Both parties agreed not to initiate further litigation or complaints against each other regarding the disputed properties.
  11. All allegations made by the parties against each other were deemed withdrawn upon filing of the Compromise Agreement.
  12. The Supreme Court accepted the settlement agreement, modified the judgments of the lower courts accordingly, and made the settlement part of the court's decree.

Study Guide

  1. Understand the Parties: Identify the two main parties involved in the dispute: Shri Jain Shwetamber Shri Sangh Panjikrit Sanstha (the Appellant) and Shri Jain Shwetamber Khartargachh Sangh (a Respondent). Understand their respective roles in the conflict and the settlement.
  2. Trace the Legal History: Review the timeline of the case, starting from the Trial Court decision in 2017, through the Rajasthan High Court appeal, and finally to the Supreme Court. Pay attention to the various case numbers and dates.
  3. Mediation Process: Analyze the role of mediation in resolving the dispute. Study the appointment of Hon’ble Mr. Justice S. Ravindra Bhat (Retd.) as mediator and the process that led to the compromise.
  4. Key Settlement Terms: Examine the specific terms of the settlement agreement. Pay close attention to how the properties were divided, the financial settlement, and the handling of bank accounts.
  5. Property Division: Note which party gained ownership of the Dadabari complex and which party gained ownership of the two temples in Ajmer. Understand the specific names and locations of these properties.
  6. Financial Settlement: Understand the monetary component of the settlement, including the amount, the method of payment, and the timing of payments.
  7. Bank Account Handling: Analyze how the bank accounts of Shri Jain Shwetamber Shree Sangh were handled under the agreement. Recognize the specific bank and account numbers involved.
  8. Resolution of Pending Cases: Explore how the settlement addressed the various pending cases in the lower courts. Understand the agreement to withdraw and close these cases.
  9. Future Litigation: Understand the agreement that prohibits future litigation between the parties. Note that the agreement includes a commitment to withdraw any allegations.
  10. Supreme Court Order: Understand the Supreme Court’s role in modifying the judgments of the lower courts and making the settlement a part of the court’s decree.
  11. Legal Terms: Familiarize yourself with key legal terms such as Appellant, Respondent, S.L.P. (C), Mediation, Compromise Agreement, Trial Court, High Court, Decree, and Art. 142.

Rationale

  1. Mediation as a Resolution Tool: The Supreme Court opted for mediation to resolve the dispute, recognizing the potential for an amicable settlement that would serve the long-term interests of both parties. This approach underscores the court’s encouragement of alternative dispute resolution methods for complex conflicts.
  2. Fair Division of Assets: The settlement aimed for a balanced distribution of assets. The Dadabari complex was assigned to Shri Jain Shwetambar Khartargachh Sangh, while the two temples in Ajmer were assigned to Shri Jain Shwetamber Shree Sangh, reflecting a negotiated agreement that took into account the history of the dispute.
  3. Financial Compensation: The financial settlement of ₹8,11,00,000 from Shri Jain Shwetambar Khartargachh Sangh to Shri Jain Shwetamber Shree Sangh was a critical part of the compromise, ensuring an equitable outcome.
  4. Clarity in Management: By explicitly defining the management rights for the properties, the settlement aimed to prevent future disputes. Each party was given clear control over specific assets, avoiding ambiguity and the potential for continued conflict.
  5. Ending Litigation: The agreement to withdraw all pending cases and refrain from future litigation was vital in bringing the long-standing conflict to a definitive end. This aimed to conserve judicial resources and ensure a lasting peace between the parties.
  6. Legal Finality: By making the settlement a part of the court’s decree, the Supreme Court ensured that the agreement was legally binding and enforceable. This move strengthened the settlement and provided a strong disincentive for future violations.
  7. Promoting Peace: The overall aim of the Supreme Court's intervention was to promote peace and stability between the two religious organizations. The settlement was structured to provide a clear, conclusive resolution that would prevent future conflicts and allow the parties to focus on their religious missions.

FAQ

Q.1. What was the main issue in this case?

Answer: The main issue was a property dispute between two Jain organizations, Shri Jain Shwetamber Shri Sangh Panjikrit Sanstha and Shri Jain Shwetamber Khartargachh Sangh, concerning the ownership and management of a Dadabari complex and two temples in Ajmer.

Q.2. How did the Supreme Court resolve the dispute?

Answer: The Supreme Court referred the matter to mediation, appointing Hon’ble Mr. Justice S. Ravindra Bhat (Retd.) as the mediator. A settlement agreement was reached through mediation, outlining the division of assets and responsibilities between the two organizations.

Q.3. Who gained ownership of the Dadabari complex?

Answer: Shri Jain Shwetambar Khartargachh Sangh gained sole ownership, possession, and management rights over the Dadabari complex and its properties.

Q.4. Which organization gained ownership of the two temples in Ajmer?

Answer: Shri Jain Shwetamber Shree Sangh was granted sole ownership and management of the two temples in Ajmer: Sambhavnath Bhagwan ka Mandir and Rishabhdev Bhagwan ka Mandir.

Q.5. How were the bank accounts of Shri Jain Shwetamber Shree Sangh handled?

Answer: Shri Jain Shwetamber Shree Sangh retained sole rights to operate and make withdrawals from their specified bank accounts at Punjab National Bank, Vaishali Nagar, Ajmer. Shri Jain Shwetamber Khartargachh Sangh was excluded from any claim on these accounts.

Q.6. What was the total monetary settlement amount?

Answer: Shri Jain Shwetambar Khartargachh Sangh agreed to pay a total sum of ₹8,11,00,000 (Rupees Eight Crores and Eleven Lakhs) to Shri Jain Shwetamber Shree Sangh.

Q.7. How was the monetary settlement paid?

Answer: ₹11,00,000 was paid at the time of the execution of the agreement, and the remaining ₹8,00,00,000 was paid at the time the Supreme Court issued its final order.

Q.8. What happened to the other pending cases between the two parties?

Answer: Both parties agreed to withdraw all pending cases in various courts, including those before Nyayalaya SDO, Ajmer, and the Rajasthan High Court. The Supreme Court ordered these cases to be closed.

Q.9. Did the settlement include a clause about future disputes?

Answer: Yes, both parties agreed not to initiate any further litigation or complaints against each other regarding the disputed properties.

Q.10. What did the Supreme Court do to finalize the settlement?

Answer: The Supreme Court accepted the settlement agreement, modified the judgments of the lower courts accordingly, and made the settlement part of the court’s decree. The court also ordered that copies of the order be sent to the lower courts to close the related cases.

Conclusion

The Supreme Court's judgment in the case of Shri Jain Shwetamber Shri Sangh Panjikrit Sanstha vs. State of Rajasthan successfully resolved a long-standing property dispute between two religious organizations through a mediated settlement. The judgment clearly defined the ownership and management rights of the disputed properties, settled the financial issues, and withdrew all pending litigation, thus preventing future conflicts. The settlement was made a part of the decree, and the Supreme Court modified the lower court’s judgments according to the settlement agreement, underscoring the Supreme Court's role in ensuring peaceful settlements. This case highlights the effectiveness of mediation in resolving complex and sensitive disputes.

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