Isabella Mariam

The High Court of Kerala Division Bench of Justice Anil K. Narendran and Justice Muralee Krishna S. dismissed a writ petition challenging the decision to shift the ‘Illam Nira’ ceremony from the Namaskara Mandapam to the area near the flag mast at Sree Guruvayur Sree Krishna Temple. The Court held that there was no reason to interfere with the Guruvayoor Devaswom Managing Committee’s resolution taken after obtaining the Tantri’s opinion, noting that the Tantri is the final authority in religious, ritual, or ceremonial matters under Section 35 of the Guruvayoor Devaswom Act. The Bench clarified that the dispute whether ‘Illam Nira’ is a religious ceremony or merely an offering is a question of fact that must be decided by a competent civil court, not in writ proceedings.

The matter before the Division Bench arose from a petition filed under Article 226 of the Constitution seeking a writ of mandamus to prevent any alteration of the venue of ‘Illam Nira’ and to ensure that customs, rituals, rites, poojas, practices, and usages at the temple are not altered. The petitioners are male members of Puzhakkara Chennas Mana, the Tantri family associated with the temple.

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The petition stated that ‘Illam Nira’/‘Nira Puthari’ is a significant and established ceremony wherein devotees bring the first yield of paddy as rice bran bundles (Nelkathir) to be placed at the eastern entrance and then taken to the Namaskara Mandapam. After a special Mahalakshmi Pooja by the melsanthi in the Namaskara Mandapam, the bundles are taken to the sanctum sanctorum and to sub-deities, following which the rice bran is distributed as prasadam to devotees. The petitioners contended that shifting the ceremony from the Namaskara Mandapam to the Kodimaram area would impair the sanctity of what they described as a holy ritual.

The Guruvayoor Devaswom Managing Committee decided to shift the venue from the Namaskara Mandapam to the area near the flag mast (Kodimaram) outside the Naalambalam by Resolution No.49 dated 07.08.2024 (marked Ext.R1(a)). In the proceedings, a communication dated 05.08.2024 from the Tantri to the Administrator recorded that, after ascertaining “Devahitham,” the proposed change would not be against the deity’s wishes. The Court’s order dated 17.08.2024, on an interlocutory consideration, recorded that in view of the Tantri’s Devahitham-based view, it was appropriate not to interfere with the conduct of ‘Illam Nira’ scheduled on 18.08.2024 in terms of Ext.R1(a).

Respondents 1 and 2 (the Committee and its Administrator) filed a counter affidavit contending that the writ petition was not maintainable, as it raised disputed questions of fact concerning the existence and nature of rituals and customs. They asserted that ‘Illam Nira’ is an offering performed once a year, connected with the agricultural calendar and distinct from the temple ritual of ‘Thriputhari’ (‘Nira Puthiri’), and that no change had been made to the age-old ritual. The counter also explained logistical considerations: the accumulation of numerous paddy bundles caused space constraints, blocked pathways, delayed cleaning, and postponed darshan—necessitating the decision to shift the venue near the flag mast for the convenience of devotees.

In a separate counter affidavit dated 05.02.2025, the Tantri stated that ‘Illam Nira’ is an offering rather than a ritual, that Mahalakshmi (Kathir) Pooja is conducted under his instructions, and that while a handful of ‘Kathir’ may be symbolically placed at the inner step of the sanctum, it is not offered as nivedyam to the idol. He described the previous practice of stacking large numbers of bundles at the Namaskara Mandapam—often up to the ceiling—which caused significant delays in cleaning and resumption of regular poojas, and in turn delayed devotees’ access for darshan. The Tantri explained that the flag-mast area is a significant space as per temple vastu and that adjustments in practice, including relocation of ceremonies, had precedent when required to manage devotees’ convenience without affecting sanctity.

An additional counter affidavit dated 26.06.2025 further clarified that ‘Illam Nira’ and ‘Niraputhiri’ are distinct ceremonies, that no pooja is conducted inside the Sreekovil specifically for ‘Illam Nira’, and that the bundles’ stacking had blocked circulation and visibility to the Sreekovil and sub-deities during earlier years. It reiterated that the relocation would allow more worshippers to offer prayers and would not affect the ceremony’s sanctity.

The Bench recorded the dates of hearing and pronouncement: the writ petition was finally heard on 08.07.2025, and judgment was delivered on 29.07.2025. The State of Kerala was suo motu impleaded as an additional respondent on 05.09.2024.

On the question presented, the Court framed the issue as whether ‘Illam Nira’ at Sree Guruvayur Sree Krishna Temple is a religious ceremony or an offering (Vazhipadu) and whether the Committee’s decision dated 07.08.2024 to shift the venue should be interfered with in the Court’s extraordinary jurisdiction under Article 226.

The judgment also noted, based on materials including the Guruvayoor Devaswom Panchangam for 1200 ME, that ‘Illam Nira’ and ‘Niraputhari’ (Triputhiri) are distinct ceremonies scheduled on different dates; ‘Illam Nira’ involves pooja to rice bran bundles brought by the petitioners’ family after the first harvest, whereas ‘Niraputhari’ relates to nivedyam from newly harvested paddy. The Court further recorded that on the eve of ‘Illam Nira’ the rice bran is not offered as nivedyam inside the sanctum sanctorum.

The Bench set out the central issue in the following terms: “The issue arises for consideration in this writ petition is as to whether the ‘Illam Nira’ ceremony at Sree Guruvayoor Sree Krishna Temple is a religious ceremony or an offering (Vazhipadu) and whether Ext.R1(a) decision dated 07.08.2024 of the 1st respondent Guruvayoor Devaswom Managing Committee to shift ‘Illam Nira’ ceremony from the Namaskara Mandapam to the area near the flag mast (Kodimaram) of the temple is to be interfered with by this Court by exercising the extraordinary jurisdiction of this Court under Article 226 of the Constitution of India?” The Court recorded this formulation at the outset.

Addressing the distinction between the two ceremonies, the Bench stated: “Though in the instant writ petition, the petitioners pleaded ‘Illam Nira’ as well as ‘Nira Puthiri’ as if one and the same religious function, during the course of arguments it was brought out before us that ‘Illam Nira’ and ‘Nira Puthiri’ are entirely different functions.” The Court noted their scheduled dates and purposes: “Illam Nira is scheduled to be held on 28.08.2025 and Niraputhari, which is also known as Triputhiri, is scheduled to be held on 02.09.2025. While Illam Nira is conducted after the 1st harvest by conducting pooja to the rice bran bundles brought to the temple by the family of the petitioners, Nira Puthiri… is connected with Nivedyam of rice collected from newly harvested paddy to the idol of the deity.”

On the nature of offerings during ‘Illam Nira’, the Bench recorded: “From the pleadings in the writ petition as well as in the counter affidavit and also from the submissions made at the Bar, it is evident that on the eve of ‘Illam Nira’ the rice bran is not offered as a Nivedyam to the idol inside the sanctum sanctorum.”

In considering the appropriate forum for resolving disputed questions, the Court referred to its earlier decision: “In view of the stand taken by the 3rd respondent Tantri… the question as to whether the performance of Udayasthamana Pooja… is a temple Acharam or tradition in Guruvayur Sree Krishna Temple has to be established before a competent civil court and the petitioners cannot agitate that disputed question of fact in a writ petition filed under Article 226 of the Constitution of India.” The Bench then noted: “Having found as above in Hary P.C [2025 (1) KHC SN 1], this Court dismissed the writ petition holding that no interference is warranted…” and applied the same principle to the present dispute concerning ‘Illam Nira’.

The Bench examined Section 35 of the Guruvayoor Devaswom Act and recorded: “As per Section 35 of the Guruvayoor Devaswom Act, the Tantri shall be the final authority in religious matters. As per sub-section 2 of Section 35, the decision of the Tantri of the temple on all religious, spiritual, ritual or ceremonial matters pertaining to the Guruvayoor Devaswom shall be final, unless such decision violates any provision contained in any law for the time being in force.”

The Court also summarised the legal position that a “legal fiction” exists in the Act concerning non-interference by civil authorities in spiritual matters, noting: “A legal fiction has been created in Section 35 of the Act, in terms whereof the committee or the commissioner or the Government is expressly prohibited from interfering with the religious or spiritual matters pertaining to the Devaswom. His decision on all religious, spiritual, ritual or ceremonial matters… is final unless the same violates any provision contained in any law for the time being in force.”

Applying these principles to the Committee’s decision, the Bench recorded the procedural step of seeking the Tantri’s opinion and its content: “As per the opinion of the Tantri dated 05.08.2024… the 3rd respondent Tantri gave an opinion after ascertaining ‘Devahitham’ that such a shifting of the venue of Illam Nira from the Namaskara Mandapam to the area near the Flag Mast or in other words near the Valiya Balikkallu is not against the wishes of Lord Guruvayoorappan.” The Court then stated: “Since the decision of the Managing Committee to shift the venue of ‘Illam Nira’ was taken after obtaining the opinion of the Tantri, even if the ‘Illam Nira’ ceremony is a religious act or only a Vazhipadu, there is no statutory violation in that decision.”

Concluding its analysis, the Bench stated: “In such circumstances, we find no reason to interfere with Ext.R1(a) decision taken by the 1st respondent Guruvayoor Devaswom Managing Committee to shift the venue of Illam Nira from Namaskara Mandapam to the place near the Flag Mast.”

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After summarising the pleadings and submissions, the Bench stated: “Having considered the pleadings and materials on record and the submissions made at the Bar, as discussed above, we find no reason to grant any of the reliefs sought for in the writ petition in favour of the petitioners.” The Court expressly recorded the outcome and the clarification that followed: “The writ petition stands dismissed. We make it clear that we have not expressed anything regarding the dispute as to whether Illam Nira is a religious ceremony or only an offering, which is an issue that has to be decided only by a competent Civil Court.”

Earlier, on an interlocutory application considered on 17.08.2024, the Bench had recorded the position and declined interference with the conduct of the ceremony on that date in terms of the Committee’s decision, noting: “…it is appropriate not to interfere with the conduct of ‘Illam Nira’ scheduled to be held on 18.08.2024, in terms of the decision taken in Ext.R1(a).”

The judgment also recorded the Court’s application of statutory principles to the facts at hand, concluding that the Committee’s decision was taken after obtaining the Tantri’s opinion on Devahitham and that “even if the ‘Illam Nira’ ceremony is a religious act or only a Vazhipadu, there is no statutory violation in that decision.”

Advocates Representing the Parties

For the Petitioners: Sri. M.P. Ashok Kumar; Smt. Bindu Sreedhar; Shri. Asif N.

For the Respondents: Smt. Meena A.; Sri. Vinod Ravindranath; Smt. M.R. Mini; Smt. Nivedhitha Prem V.; Sri. S. Rajmohan, Sr. Government Pleader; Sri. T.K. Vipindas, Standing Counsel, Guruvayoor Devaswom Board.

Case Title: P.C. Krishnan & Ors. v. Guruvayoor Devaswom Managing Committee & Ors.
Neutral Citation: 2025:KER:52884
Case Number: WP(C) No. 28969 of 2024.
Bench: Justice Anil K. Narendran; Justice Muralee Krishna S.