- Facts
The case arose from one of the most contentious disputes in independent India, concerning ownership of a 2.77-acre parcel of land in Ayodhya, Uttar Pradesh. Hindus considered it the birthplace (janmasthan) of Lord Ram, while Muslims considered it the site of the Babri Masjid, constructed in 1528 by Mir Baqi, a general of the Mughal emperor Babur.
In 1857, the colonial administration erected a railing at the site to prevent conflict, separating the inner courtyard (where Muslims prayed) from the outer courtyard (where Hindus worshipped at the Ram Chabutra and Sita Rasoi). This arrangement continued until December 1949, when idols of Lord Ram were placed under the central dome of the mosque, leading to the attachment of the site under Section 145, Code of Criminal Procedure, 1898. [1]
On 6 December 1992, the Babri Masjid was demolished by kar sevaks, leading to widespread communal riots across India.
Multiple suits were filed:
• Suit 3 (1959): Nirmohi Akhara claimed managerial rights as shebaits.
• Suit 4 (1961): Sunni Central Waqf Board claimed ownership and possession of the mosque.
• Suit 5 (1989): “Shri Ram Lalla Virajman,” treated as a juristic entity, claimed ownership of the entire land.
The Allahabad High Court in M. Siddiq v. Mahant Suresh Das (2010) 2010 SCC OnLine All 8436, divided the land equally among three parties—Sunni Waqf Board, Nirmohi Akhara, and Shri Ram Lalla.
Appeals were filed in the Supreme Court. A five-judge bench comprising Chief Justice Ranjan Gogoi and Justices S.A. Bobde, D.Y. Chandrachud, Ashok Bhushan, and S. Abdul Nazeer heard the matter. The unanimous judgment was delivered on 9 November 2019: M. Siddiq (D) Thr Lrs v. Mahant Suresh Das & Ors., (2020) 1 SCC 1.
- Issues Raised
• Whether the Allahabad High Court was correct in dividing the land into three parts despite the absence of joint possession?
• Whether Shri Ram Lalla Virajman and Ram Janmabhoomi could be recognized as juristic persons under Indian law?
• Whether the Sunni Central Waqf Board could establish valid title or adverse possession?
• Whether Nirmohi Akhara had enforceable shebait rights?
• How should courts balance religious faith with evidentiary standards under property law?
• Whether equitable relief in the form of alternative land could be awarded to Muslims if their claim failed?
3. Contentions
A. Sunni Waqf Board
• Claimed Babri Masjid was a lawfully constructed mosque on Waqf property, protected under Waqf Act, 1954 (and later Waqf Act, 1995).
• Asserted continuous possession and worship by Muslims until 1949.
• Argued adverse possession extinguished Hindu claims.
B. Nirmohi Akhara
• Claimed shebaitship rights, citing precedents like Deoki Nandan v. Murlidhar, AIR 1957 SC 133, where shebaits were recognized as custodians of deity’s property.
• Sought restoration of management rights over the temple.
C. Shri Ram Lalla Virajman
• Asserted juristic personality of the deity, citing Yogendra Nath Naskar v. CIT, AIR 1969 SC 1089.
• Claimed Hindus never relinquished possession and continued to worship at both courtyards.
• Relied on ASI report indicating a non-Islamic structure beneath the mosque.
D. State of Uttar Pradesh / Union of India
• Submitted that government would follow court’s directive.
• Urged for peaceful resolution given the sensitive nature of the dispute.
4. Rationale of the Supreme Court
(i) Juristic Status of Deity
The Court held that Shri Ram Lalla Virajman is a juristic person under Hindu law, relying on precedents such as Pramatha Nath Mullick v. Pradyumna Kumar Mullick[2], AIR 1925 PC 139, and Yogendra Nath Naskar. It further held that even the land (janmasthan) could be treated as a juristic entity.[3]
(ii) Allahabad High Court’s Partition
The tripartite division was set aside. The Court held that partition could not be judicially imposed absent evidence of joint possession. Property rights must follow proof of title.[4]
(iii) Muslim Claim
The Sunni Waqf Board failed to prove continuous exclusive possession. Evidence of namaz prior to 1857 was scant. Claims of adverse possession were rejected, as Hindus persistently contested possession.[5]
(iv) Hindu Worship and Possession
The Court found consistent evidence of Hindu worship in the outer courtyard since before 1857, and in the inner sanctum after 1949. Faith in Ram Janmabhoomi was held to be “legally relevant.”[6]
(v) Archaeological Evidence
The ASI report (2003) confirmed a non-Islamic structure beneath the mosque. While not definitive of demolition, it rebutted the claim of construction on vacant land.[7]
(vi) Equitable Relief
Recognising Muslim dispossession after 1949, the Court ordered the State to allot 5 acres of land in Ayodhya to the Sunni Waqf Board under Article 142 of the Constitution to do “complete justice.”[8]
(vii) Final Holding
The Court unanimously decreed the entire disputed land to Shri Ram Lalla Virajman, to be managed by a trust created by the Union of India under the Acquisition of Certain Area at Ayodhya Act, 1993.
5. Defects of Law
• High Evidentiary Burden: The requirement for Muslims to prove possession from 1528 onwards was practically impossible given historical records. Critics argue this standard unfairly tilted against them.
• Expansion of Juristic Personality: Extending juristic status to the land itself was unprecedented, arguably blurring secular boundaries.
• Reliance on Archaeology: Use of ASI evidence, though contested, was treated as determinative without cross-examination, raising procedural concerns.
• Selective Equity: Muslims were granted alternate land, but their centuries-old worship at Babri Masjid was extinguished, raising questions of neutrality.
• Political Underpinnings: The judgment, while couched in legal reasoning, clearly reflected awareness of political consequences, creating debate on judicial independence.
6. Inference
The Ayodhya verdict is a landmark in Indian jurisprudence, both for resolving a centuries-old conflict and for testing the limits of secular adjudication.
• It reaffirmed long-standing Hindu law doctrines on deities as juristic persons.
• It showed judicial pragmatism in balancing competing faiths through the grant of alternative land.
• It brought closure to one of the longest and most politically sensitive litigations in India.
Yet, it also left unresolved questions about the line between faith and law, evidentiary standards in historical disputes, and the Court’s role in communal conflicts.
The case thus represents pragmatic constitutionalism: the Court sought not merely to decide a title dispute, but to preserve communal harmony and national stability. Whether it succeeded in balancing law with faith without diluting secular principles will remain debated for decades to come.
7. Conclusion
The judgment delivered in M. Siddiq (D) Thr Lrs v. Mahant Suresh Das & Ors. On 9 November 2019 stands as a historic landmark in the constitutional and judicial history of India. The case, popularly known as the Ayodhya land dispute case, was not merely a contest over property rights but a deeply sensitive conflict intertwined with questions of faith, history, and secularism. The Supreme Court, in its unanimous verdict, attempted to resolve a centuries-old dispute by striking a delicate balance between religious sentiments and legal principles.
At its core, the decision reaffirmed the supremacy of the rule of law. The Court carefully distinguished between questions of faith and questions of title, emphasizing that belief in the birthplace of Lord Ram could not itself confer ownership. Instead, the adjudication rested on established doctrines of evidence, possession, and adverse claims under property law. By holding that the Hindu parties successfully demonstrated continuous worship and possession over the outer and inner courtyards, the Court rooted its decision in tangible legal principles rather than religious dogma.
Equally significant was the Court’s recognition of the illegality of the demolition of the Babri Masjid in 1992, labeling it an “egregious violation of the rule of law.” By acknowledging this wrong, the Court underscored that unlawful acts could not be legitimized retroactively, even though the final outcome awarded the disputed land to the Hindu claimants. To balance this, the Court directed the allotment of five acres of alternative land to the Sunni Waqf Board for the construction of a mosque, thereby attempting to preserve the secular fabric of the Constitution and the principle of equal respect for all religions.
From a constitutional perspective, the judgment reflects a pragmatic approach. By invoking Article 142, the Supreme Court exercised its extraordinary powers to do “complete justice” and provide a workable solution in a case where legal complexities intertwined with deep-rooted religious and political tensions. This move, though criticized by some as judicial overreach, reflects the Court’s awareness that its ruling would not only decide property rights but also determine the future of communal harmony in India.
However, the decision has not been free from criticism. Scholars argue that despite acknowledging the illegality of the mosque’s demolition, the Court ultimately rewarded the party associated with that act, thereby raising questions about the consistency of legal accountability. Others maintain that the judgment, while legally reasoned, inevitably leaned towards majoritarian sentiments to secure long-term peace. Thus, it reflects both the strength and the limitations of judicial decision-making in cases of profound religious conflict.
In conclusion, the Ayodhya judgment represents a moment where the Indian judiciary sought to reconcile law, faith, and history in a manner aimed at preserving peace and social order. Its legacy lies not only in resolving a long-standing dispute but also in demonstrating the judiciary’s role as a custodian of constitutional values in the face of deeply divisive issues. Whether viewed as an act of pragmatic statesmanship or as a compromise with constitutional morality, the case will remain a defining precedent in the dialogue between religion, law, and secularism in India.
[1] S.145 CrPC, 1973
[2] Pramatha Nath Mullick v. Pradyumna Kumar Mullick , AIR 1925 PC 139.
[3] M Siddiq (D) Thr Lrs v. Mahant Suresh Das & Ors. 2020 (1) SCC 1,¶§ 104–116
[4] M Siddiq (D) Thr Lrs v. Mahant Suresh Das & Ors 2020 (1) SCC 1,¶§ 787–790
[5] M Siddiq (D) Thr Lrs v. Mahant Suresh Das & Ors 2020 (1) SCC 1,¶§ 794–805
[6] M Siddiq (D) Thr Lrs v. Mahant Suresh Das & Ors 2020 (1) SCC 1,¶§ 768–772
[7] M Siddiq (D) Thr Lrs v. Mahant Suresh Das & Ors 2020 (1) SCC 1,¶§ 783–784
[8] M Siddiq (D) Thr Lrs v. Mahant Suresh Das & Ors 2020 (1) SCC 1,¶§ 807–809