Madras HC: Chidambaram temple keeps Article 26 rights, but a Board takes over for upkeep

In a common order on three writ petitions filed under Article 226, the Madras High Court decided whether a 2022 Tamil Nadu government order on darshan timings at the Nataraja Temple, Chidambaram, was a colourable attempt to override the Podhu Dikshitars' constitutional right as a religious denomination to administer the temple under Articles 25 and 26. The Bench answered that question "No": the order was not unconstitutional interference with the denomination's rights. But on two linked questions, it found "Yes" that the temple's heritage structure had been damaged under the Dikshitars' management, disguised as renovation, and "No" that the temple's movable and immovable properties had been properly accounted and audited.

The Court held that under Article 26(d), a denomination's right to manage its own religious institution's property can be curtailed only to cure proved maladministration, and only for as long as the evil persists — permanent government control is impermissible. Applying that test, it did not hand the temple to the state's Hindu Religious and Charitable Endowments Department. Instead it constituted a separate Board of Management, funded by HR&CE but independent of it, to retrieve encroached temple assets, audit accounts, restore damaged heritage structures and ensure the public can access the Kanagasabai shrine, while leaving daily rituals and festivals exclusively to the Podhu Dikshitars.