Kerala High Court Upholds Thanthri’s Authority, Denies Devotee’s Request to Include Palpayasam Offering in Daily Paditharam for Sub-Deity, Citing Temple’s Rituals

Court’s Decision

The Kerala High Court ruled against the petitioner’s request to formalize a specific offering (“vazhipadu”) as part of the Paditharam (daily rituals) for the Sub-Deity, Muralikrishna, at the Kunnamthanam Madathilkavu Bhagavathy Temple. The court emphasized that the opinion of the temple Thanthri (chief priest) is authoritative in matters concerning temple rituals. Therefore, the petitioner’s plea to include the “palpayasam” (sweet milk porridge) vazhipadu as a daily ritual was declined.

Facts

The petitioner, a devotee, filed a complaint with the Ombudsman for the Travancore Devaswom Board, expressing concern that the Board had yet to implement an arrangement for regular Paditharam in the Muralikrishna Temple. The petitioner claimed the lack of formalized Paditharam had placed a financial burden on him, as he had been funding the “palpayasam” vazhipadu on a daily basis. Receipts were presented as evidence of this personal expense.

The Travancore Devaswom Board, which manages over a thousand temples, took the stance that since the Muralikrishna deity is a Sub-Deity of the main Bhagavathy Temple, the daily Paditharam did not extend to this deity. The Thanthri affirmed that specific offerings (vazhipadus) made by devotees are not mandated as daily rituals and can be discontinued at any time.

Issues

1. Whether a devotee has the right to demand that a specific offering be included in the temple’s daily Paditharam.
2. Whether the temple administration or Thanthri can decide on the ritual obligations, particularly for a Sub-Deity.

Petitioner’s Arguments

The petitioner argued that the Devaswom Board had previously implied an intent to formalize the Paditharam for the Sub-Deity. He contended that his daily contributions should lead to an official recognition of the ritual, relieving him of personal financial responsibility.

Respondent’s Arguments

The Devaswom Board and Thanthri contended that the Paditharam structure, based on long-standing customs and traditions, does not mandate daily rituals for Sub-Deities. The Board highlighted that each vazhipadu performed by devotees is optional, not obligatory under temple customs.

Analysis of the Law

The Court examined Chapter II of the Travancore Devaswom Manual, which governs rituals in Devaswom-managed temples. This chapter entrusts the temple Thanthri with the authority to define and regulate rituals, with specific provisions for “Pathivu” and “Paditharam” ceremonies. The manual does not stipulate Paditharam requirements for Sub-Deities, placing discretion with the Thanthri and Board.

Precedent Analysis

The Court referenced the established principles of temple ritual management under the Travancore Devaswom Manual. The decision reinforced the principle that devotees cannot unilaterally enforce specific offerings as daily rituals and that the Thanthri’s authority in ritual matters is paramount.

Court’s Reasoning

The Court reasoned that including the palpayasam vazhipadu as part of the official Paditharam would violate the temple’s traditional practices as upheld by the Thanthri’s discretion. It noted that the petitioner’s continued offering of palpayasam, while commendable, does not entitle him to impose it as a compulsory ritual. Additionally, the Board is responsible for performing the required Nityanidhanam and Masavisesham ceremonies in accordance with established customs.

Conclusion

The Kerala High Court concluded that the petitioner has no right to compel the Board to adopt the palpayasam offering into the daily Paditharam for the Sub-Deity. The Court upheld the Thanthri’s authority and closed the petition.

Implications

This judgment reaffirms the Thanthri’s authority in determining temple rituals and restricts individual devotees from imposing personal offerings as official practices. This ruling may influence future cases where devotees seek to formalize specific rituals in Devaswom-administered temples, emphasizing adherence to tradition and the discretionary power of temple authorities.

Also Read – Supreme Court Partly Allows Appeal in Land Dispute Case: Conviction Reduced from Murder to Culpable Homicide Due to Lack of Premeditation and “Sudden Heat of Passion” Under Section 304 Part I, IPC