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Issues Involved:
1. Whether the petitioners/respondents can challenge the State's right to manage Shri Rikhabdevji temple. 2. Whether the provisions of the Rajasthan Public Trusts Act, 1959 infringe the fundamental rights to manage religious affairs and administer property under Articles 25 and 26 of the Constitution. 3. Validity of Section 17(3) of the Act regarding the registration fee. 4. Validity of Sections 52(1)(d) and (e) and Section 53 of the Act regarding the management of public trusts. 5. Whether the temples in question are private or public religious trusts. Issue-wise Detailed Analysis: 1. Challenge to the State's Right to Manage Shri Rikhabdevji Temple: The High Court held that Shri Rikhabdevji temple is a Swetamber Jain temple managed by the State of Rajasthan. The State argued it was a Hindu temple, but the Court found no evidence to support this. Historical documents and official records consistently referred to the temple as a Jain temple. The management of the temple had vested in the State prior to the Constitution under a valid law, and this right continued post-Constitution. Therefore, any pre-Constitution rights of the Jains to manage the temple were deemed lost, and the State's management was upheld. 2. Infringement of Fundamental Rights under Articles 25 and 26: The respondents claimed that the Act infringed their rights under Articles 25 and 26 to manage religious affairs and property. The Court noted that the right to manage religious affairs (Art. 26(b)) and administer property (Art. 26(d)) are distinct. Since the management had vested in the State pre-Constitution, the respondents could not reclaim it post-Constitution under these Articles. The Court relied on precedents that held if a right was lost pre-Constitution, it could not be revived post-Constitution. 3. Validity of Section 17(3) of the Act: Section 17(3) was challenged on the grounds that the registration fee was a tax beyond the State Legislature's competence. The High Court found the fee invalid as it was credited to the Consolidated Fund, making it a tax. However, the Supreme Court reversed this, stating the fee was a contribution towards the expenses incurred by the State in rendering services to public trusts. The expenditure on the Devasthan Department far exceeded the income from the fee, thus it was a fee and not a tax. 4. Validity of Sections 52(1)(d) and (e) and Section 53: The High Court struck down Sections 52(1)(d) and (e) and Section 53 for not providing safeguards for leaving the administration of the property in the hands of the denomination. The Supreme Court disagreed, interpreting Section 53 to mean that the State Government must consider the wishes of the persons interested in the trust while appointing the Committee of management. The Court held that these provisions, when read correctly, did not violate the fundamental rights under Articles 25 and 26. 5. Private vs. Public Religious Trusts: In the case of the temples managed by Pandit Ram Dayal, the High Court did not address whether they were private or public trusts. The Supreme Court noted that this issue was not agitated before the High Court and should be decided by the appropriate authority under the Act before applying the Act to these temples. Conclusion: The Supreme Court allowed the State's appeals, setting aside the High Court's directions regarding the management of Shri Rikhabdevji temple and the invalidation of Sections 17(3) and 52(1)(d) and (e). The respondents' appeals were dismissed. Each party was ordered to bear its own costs.
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