Facts of the case:-
In the annals of Indian history, the district of Ayodhya in Uttar Pradesh stands as a testament to both ancient legend and modern controversy. At the heart of this saga lies a 2.77-acre plot of land, known by its plot number 583, which became the epicenter of India’s most protracted and contentious land dispute.
Ancient lore intertwines with historical accounts like hindu legendary books like Ramayan, Bhavisya Puran also the scripts of Lomesh Ramayan, tracing Ayodhya’s origins back to 500 BC when it served as the capital of the Kosala kingdom. Legends speak of Maharaja Kush, son of Lord Ram, erecting the first Ram temple on the grounds of his father’s birthplace. Through the passage of time, 44 successive kings ruled over this sacred land, until the advent of the Mahabharata era, marked by the demise of Maharaja Brihadbala in the famed battle by Abhimanyu.
In 57 AD, the illustrious Maharaja Vikramaditya of Ujjain ventured to Ayodhya, captivated by its rich history and spiritual aura. Inspired by the tales of yore, he embarked on a grand endeavour to rejuvenate the Ram temple and revitalize the city, bestowing upon it newfound splendour and grandeur.
However, the winds of change swept across Ayodhya in 1526 with the arrival of Emperor Babur, heralding a tumultuous period of religious upheaval. Temples fell, mosques rose, as Babur sought to assert his dominion over the land. This information is mentioned in books like Tarikh-I-Avadh by Muhammad Qasim, Akbar-I-Masud by Abd al Qadir. It was in 1528 that the Barbri Masjid, commissioned by Babur’s commander Mir Baqi, was erected on the sacred soil of Kot Ram Chandra, forever altering Ayodhya’s destiny.
Centuries passed, and Ayodhya bore witness to the ebb and flow of history, until the late 1850s ushered in the specter of communal discord. The colonial authorities intervened, erecting a wall to quell tensions, yet strife simmered beneath the surface. In 1885, Mahant Raghubar Das’s plea to construct a temple in the outer courtyard was rebuffed by the courts, fearing unrest.
The year 1949 marked a pivotal juncture, as the idols of Lord Ram were clandestinely installed within the central dome of the disputed structure, igniting communal tensions. Legal wrangling ensued, culminating in the Faizabad Civil Court’s decision to lock down the disputed land in 1950.
However, the deadlock was shattered in 1986 when the district judge ordered the gates to be opened, granting Hindus the right to worship within the precincts. This newfound access ultimately precipitated the tragic events of December 6, 1992, when 2,00,000 Karsevaks razed the Babri Masjid to the ground.
In mindset of confusing legal situation, various claimants emerged, each vying for control over the disputed site. The Nirmohi Akhara, the Sunni Central Board of Waqf, and the Hindu deity Lord Ram Lalla Virajman, represented by former Justice Deoki Nandan Agarwal, all staked their respective claims, further entrenching the legal quagmire. Thus the present case was filed in Allahabad High Court where the court bifurcated the disputed land into 3 parts – the inner courtyard for the Lord Ram, the Ram Chabutra and Sita Rasoi to the Nirmohi Akhara, and the remaining area to the Sunni Board. However, none of the parties were satisfied and appealed to Supreme court where a 5 judges bench was formed, headed by former Chief Justice of India Ranjan Gogoi, former CJI SA Bobde, Chief Justice of India DY Chandrachud and former Supreme Court judges Ashok Bhushan and S Abdul Nazeer, the final verdict was declared on 9th November 2019.
Issues raised:-
- Was the division made by Allahabad high court between Nirmohi Akhara Sunni Board and Ram Lalla valid?
- Are the three suits maintainable and are not barred from limitation act of 1908?
- Does the Ramjanma Bhoomi can be regarded as juristic person?
- Whether a previous Hindu temple was demolished or modified to construct a mosque by Babur?
Contentions:-
- Ram Lalla Virajman:- The written submission of Ram Lalla Virajman stated that the disputed land belongs to them, that the disputed land was the birthplace of Lord Ram and is capable to be regarded as juristic person.
- Nirmohi Akhara:- Nirmohi Akhara contended that, it had the custody and should be authorized to manage the premises once the temple is built. The petitioner claimed that it had the right to perform puja and other religious ceremonies at the disputed site and sought the title to the disputed land.
- Sunni Waqf Board:- It contended that, the Masjid was constructed by the commander of Babur. The Sunni Waqf Board, representing the Muslim community, argues that the land historically belonged to them and was endowed for religious purposes. They contend that the Babri Masjid was a place of worship for Muslims for centuries and its demolition was unlawful. The Board seeks to reclaim ownership of the land and rebuild a mosque on the site. Their contentions are based on historical records, religious significance, and legal rights concerning Waqf properties.
- Bhavya Ram Janmabhoomi Trust: The Bhavya Ram Janmabhoomi Trust contends that Ayodhya holds immense religious significance as the birthplace of Lord Ram. They argue that a Hindu temple existed on the disputed site prior to the construction of the Babri Masjid. The Trust asserts rightful ownership based on historical, archaeological, and legal grounds, emphasizing Hindu rights and sentiments recognized by the Supreme Court’s verdict in 2019.
- The Uttar Pradesh Sunni Central Waqf Board:- The Uttar Pradesh Sunni Central Waqf Board contends that the disputed land historically belonged to the Muslim community as a Waqf property, housing the Babri Masjid until its unlawful demolition in 1992. They assert their legal rights to the land under Waqf laws and emphasize the need to protect minority rights in any decision regarding the site.
Rationale:
The dispute over the Babri Masjid-Ram Janmabhoomi site in Ayodhya, India, was rooted in conflicting claims of possession and historical significance. The Muslim petitioners argued for possession based on adverse possession since 1528, but the court rejected this, citing evidence of unimpeded Hindu access to parts of the disputed site. The court also noted that there was no evidence of exclusive Muslim possession before 1857. The Supreme Court granted the entire 2.77 acres of disputed land in Ayodhya to the deity Ram Lalla. The Supreme Court ordered the government of Central and Uttar Pradesh to allocate 5-acre alternative land to Muslims in a prominent location to build a mosque. The court asked the Centre to consider giving some sort of representation to Nirmohi Akhara for setting up a trust. Nirmohi Akhara was the third party to the Ayodhya conflict. The Supreme Court rejected the plea of Nirmohi Akhara, who sought to control all of the disputed lands, claiming that it was its custodian.
The court emphasized that the dispute should be seen as a whole, rejecting the division of the site into inner and outer courtyards in 1856-57 as irrelevant to determining possession. It acknowledged Hindu prayers at the inner courtyard before British annexation in 1857.
Contrary to the 2010 Allahabad High Court verdict, which heavily considered faith and belief, the Supreme Court based its decision on evidence rather than theological interpretations. It emphasized secularism and equality before the law for all faiths.
The court disregarded the Archaeological Survey of India’s report, stating that title to the land should be decided based on legal principles and evidentiary standards, not archaeological findings. It dismissed the High Court’s trifurcation of the site, stating it defied logic and was contrary to settled legal principles.
Inference:-
The judgment delivered by the Supreme Court effectively brings an end to one of the longest-running disputes in India, marking a significant milestone in the country’s legal history. From my perspective, regardless of the deep-seated religious sentiments associated with the case, the Court’s decision reflects a commendable commitment to impartiality, focusing solely on the facts and evidence presented before it. By prioritizing legal principles and evidentiary standards over religious beliefs, the Court has not only resolved the dispute but also set a precedent for harmonious conflict resolution in highly contentious matters. As a law student, it seems to me that I find myself in agreement with the Court’s decision, as it underscores the importance of adhering to the rule of law and upholding justice, irrespective of religious affiliations. As far as I’m concerned, the Court’s meticulous consideration of the evidence and its determination to deliver a fair and just verdict serve as a testament to the integrity of India’s judicial system.