Isabella Mariam

The High Court of Kerala Division Bench of Justice Raja Vijayaraghavan V and Justice K.V. Jayakumar issued a detailed judgment prescribing a structured framework to manage the heavy daily pilgrim inflow to the Sreekrishna Temple, Guruvayur. The Court directed the Devaswom Managing Committee to introduce a scientifically planned system addressing crowd regulation, capacity assessment, time-slot organisation, and essential amenities for devotees. It also ordered the formation of a permanent seven-member multi-departmental committee comprising senior officials from the district administration, police, health services, municipal authorities, environmental oversight bodies, sanitation authorities, and the Devaswom sector.

The proceedings arose from multiple petitions concerning crowd management, queue systems, and darshan facilities at the Sree Krishna Temple in Guruvayoor. The first petitioner sought reconsideration of the temple authority’s decision refusing reintroduction of the online virtual queue system, stating that increasing numbers of devotees and prolonged waiting times created difficulties for elderly persons, women, children, and differently-abled visitors. He relied on earlier directions issued by the Court to reconsider his request. A second petitioner highlighted hardships faced by devotees standing in long queues and pointed to insufficient infrastructure. A third petitioner detailed her experience during a festival, leading to registration of a related Devaswom Board Petition.

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The Guruvayoor Devaswom filed a detailed counter affidavit explaining that online booking was introduced during the COVID-19 lockdown but was discontinued due to ritual constraints, unpredictable pooja timings, and conflicts between online and offline queues. It maintained that hybrid systems were not viable owing to temple practices structured by the Thantri. The statutory framework referenced included the Guruvayoor Devaswom Act, 1978, particularly provisions relating to the powers and duties of the Managing Committee, its responsibility to provide facilities to worshippers, and the Thantri’s authority in religious matters.

The Court observed: “As the number of pilgrims increases daily, overcrowding in Guruvayoor has become a municipal-level civic challenge, not merely a temple-management problem. While the influx brings economic growth, it also raises concerns regarding sanitation, health, environment, traffic regulation, and law and order.”

The Court recorded that the issues “pertain to the queue system, crowd management, and related matters in Sree Krishna Temple, Guruvayoor.” It stated that the petitioner in the lead matter sought reintroduction of the online booking facility, asserting that “the present system of an unending queue poses serious difficulties for devotees.” It noted that another petitioner highlighted “the hardships and difficulties faced by devotees who stand in the queue for hours every day,” while a third petitioner described her “bitter experience… during the Ekadashi festival in 2024.”

Referring to the counter affidavit, the Court observed that the Devaswom authorities explained that online booking was introduced “during the lockdown of the COVID-19 pandemic,” but after resumption of normal procedures, “the timing and duration of poojas cannot be precisely predicted,” causing difficulties in adhering to allotted slots. It recorded the assertion that conflicts had arisen because devotees using online reservations “demanded priority over the other devotees who came to darshan physically,” leading to the discontinuation of the hybrid system.

The Court extracted statutory provisions, noting that Section 10(b) of the Guruvayoor Devaswom Act imposed a duty “to provide facilities for the proper performance of worship by the worshippers,” and Section 10(d) required the Committee “to ensure maintenance of order and discipline and proper hygienic conditions in the Temple.” The Court stated that these provisions “clearly state that the Guruvayoor Devaswom is bound to protect the interests of the devotees.”

It cited Supreme Court precedent that temple authorities may regulate timing and entry to ensure “good order and decency of worship and prevent overcrowding.” The Bench further recorded observations regarding the hardships caused by prolonged standing, stating that queues during peak periods may last “8 to 12 hours.” It remarked that a significant drawback of the current system is the “total absence of real-time information,” adding that the problem “can and should be resolved through a digitally integrated mobile application.”

Regarding feasibility concerns raised by the Devaswom, the Court stated that while ritual closures create unpredictability, “technology can be adapted to complement, not compromise, traditional tantric practices.” It then observed that “it is high time that a new, modern, scientifically-designed system is introduced,” and emphasised that the Managing Committee has a “sacred legal and moral duty to safeguard the welfare of devotees.”

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The Court directed that “a detailed study must be conducted to determine the maximum number of devotees the temple can safely accommodate” and that “the daily cap shall thereafter be fixed accordingly. There shall be one designated entry and one designated exit point to streamline movement.” Devotees “may be grouped (A, B, C, D, etc.)” and “each group shall be allotted tentative time slots.” It required the development of a mobile application providing “real-time updates.” At least two days a week may be dedicated exclusively for online booking” and that adequate amenities “must be provided.” It mandated priority arrangements for vulnerable groups and ordered the formation of a “permanent multi-departmental committee.” It concluded that the Devaswom must place an action plan before the Court within two months.

Advocates Representing the Parties

For the Petitioners: Sri. P. N. Damodaran Namboodiri, Shri. Hrithwik D. Namboothiri, Smt. Varada K. Hari, Sri. K. Mohanakannan and Shri. Adarsh Mohan K, Smt. Lekha Suresh

For the Respondents:
Sri. Vipin Das, Standing Counsel for Guruvayoor Devaswom;

Case Title: P. N. Radhakrishnan v. State of Kerala & Others
Neutral Citation: 2025:KER:89186
Case Number: WP(C) 41543/2024; WP(C) 5136/2025; DBP No.1/2025
Bench: Justice Raja Vijayaraghavan V, Justice K. V. Jayakumar