Dismissed¶35

The Executive Officer, v. T.Thirunavukarasu

Madras HC11 Dec 2025WA(MD)/1484/2022

Case brief

AI extract

What is this about?

Maintainability of a writ appeal under Clause 15 of the Letters Patent by an HR&CE Executive Officer acting as Special Officer of a temple: 'person aggrieved' requirement, absence of infringement of rights, and public-interest filings not conferring locus standi; writ appeal dismissed as non-maintainable (Madras High Court, Madurai Bench, 11.12.2025); concerns Arulmighu Senthatti Ayanar Temple, Keelamarainadu Village, Sivakasi Taluk, Virudhunagar District, and the Single Judge's order dated 08.04.2022 in W.P.(MD)No.23698 of 2018.

What did the court decide?

Writ appeal dismissed as non-maintainable; no costs; connected miscellaneous petition (C.M.P.(MD)No.12265 of 2022) closed. No adjudication on the merits of the impugned Single Judge order. ¶35

The Executive Officer, Vs T.Thirunavukarasu — Madras HC (2025) — LawSathi Research

What the court decided

AI extract

Outcome

Writ appeal dismissed as non-maintainable; no costs; connected miscellaneous petition (C.M.P.(MD)No.12265 of 2022) closed. No adjudication on the merits of the impugned Single Judge order.

¶35

Issue for consideration

Whether the Executive Officer of Arulmighu Vishavanatha Swamy Temple, officiating as Special Officer of the petition-mentioned temple (Arulmighu Senthatti Ayanar Temple, Keelamarainadu Village, Sivakasi Taluk, Virudhunagar District), qualifies as a 'person aggrieved' with locus standi to maintain the writ appeal under Clause 15 of the Letters Patent against the Single Judge's order dated 08.04.2022 in W.P.(MD)No.23698 of 2018.

¶29

Court's answer

Under Clause 15 of the Letters Patent, only a person aggrieved can maintain an appeal.

¶34

Ratio / Principle

None of the rights of the appellant (the Executive Officer officiating as Special Officer, appointed pursuant to the direction of this Court) have been infringed; therefore he cannot be said to be a person aggrieved.

¶34

Key takeaways

Filing the writ appeal in public interest and in the interest of the temple and devotees does not by itself confer locus standi on the Special Officer.ratio¶35
The appellant clearly lacks the locus standi to maintain the writ appeal, which is accordingly dismissed as non-maintainable.ratio¶35

Detailed headnote1 paragraphs

Madras High Court (Madurai Bench), Bench of G.R.Swaminathan and R.Kalaimathi, JJ. (judgment by G.R.Swaminathan, J.), 11.12.2025 — In W.A.(MD)No.1484 of 2022, the Executive Officer of Arulmighu Vishavanatha Swamy Temple, officiating as Special Officer of the petition-mentioned Arulmighu Senthatti Ayanar Temple, Keelamarainadu Village, Sivakasi Taluk, Virudhunagar District, appealed under Clause XV of the Letters Patent against the Single Judge's order dated 08.04.2022 in W.P.(MD)No.23698 of 2018. Held: Clause 15 of the Letters Patent permits only a person aggrieved to maintain an appeal; none of the appellant's rights were infringed, he being merely a Special Officer appointed pursuant to the direction of this Court, and filing in public interest or in the interest of the temple and devotees confers no locus standi. The writ appeal was dismissed as non-maintainable, without costs, and the connected C.M.P.(MD)No.12265 of 2022 was closed; the merits of the impugned order were not examined.

¶1

W.A.(MD)No.1484 of 2022

¶2

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

¶3

DATED : 11.12.2025

¶4

CORAM

¶5

THE HONOURABLE MR.JUSTICE G.R.SWAMINATHAN and THE HONOURABLE MRS.JUSTICE R.KALAIMATHI

¶6

W.A.(MD)No.1484 of 2022

¶7

and

¶8

C.M.P.(MD)No.12265 of 2022

¶9

The Executive Officer, Arulmigu Vishavanatha Swamy Thirukkovil, I/c, Special Officer, Arulmigu Senthatti Ayanar Thirukovil, Keelanmarainadu Village, Sivakasi Taluk, Virudhunagar District.

... Appellant

Vs.

1.T.Thirunavukarasu

2.The District Collector, Virudhunagar District, Virudhunagar.

¶14

3.The Assistant Commissioner, Hindu Religious and Charitable Endowment Department, Virudhunagar Division, Virudhunagar District.

¶15

4.S.Rajendran

¶16

5.Muthaiah ... Respondents

¶17

1/4

¶18

https://www.mhc.tn.gov.in/judis

¶19

W.A.(MD)No.1484 of 2022

¶20

Prayer : Writ Appeal filed under Clause XV of Letters Patent, to allow the writ appeal by setting aside the order dated 08.04.2022, passed in W.P.(MD) No.23698 of 2018 on the file of this Court.

¶21

For Appellant : Mr.P.Mahendran

¶22

For Respondents : Mr.R.G.Shankar Ganesh for R1 Mr.J.K.Jayaseelan, Government Advocate for R2 & R3. Mr.S.Madhavan for R4 Mr.M.Thirunavukkarasu for R5

¶23

JUDGMENT

¶24

(By G.R.SWAMINATHAN, J.)

¶25

Heard both sides.

¶26

2.The Executive Officer of Arulmighu Vishavanatha Swamy

¶27

Temple who has been officiating as Special Officer of the petition mentioned temple namely, Arulmighu Senthatti Ayanar Temple, Keelamarainadu Village, Sivakasi Taluk, Virudhunagar District has filed

¶28

this writ appeal questioning the order dated 08.04.2022 passed by the learned Single Judge in W.P.(MD)No.23698 of 2018.

¶29

3.We fail to understand as to how an Executive Officer can be said

¶30

to be a person aggrieved. A writ appeal is filed under Clause 15 of the

¶31

2/4

¶32

https://www.mhc.tn.gov.in/judis

¶33

W.A.(MD)No.1484 of 2022

¶34

Letters Patent. It specifically states that only a person aggrieved can maintain an appeal. None of the rights of the appellant herein have been infringed. He is only a Special Officer who was appointed pursuant to the direction of this Court. The learned counsel for the appellant would point out that only after the Executive Officer assumed charge as Special Officer, order was brought in the administration of the temple which otherwise was riven by internal and factional disputes.

¶35

4.The Special Officer might have filed the writ appeal in public interest and in the interest of temple and devotees. But that itself will not confer locus standi on the appellant herein. We are clearly of the view that the appellant lacks the locus standi to maintain the writ appeal. The writ appeal is dismissed as non maintainable. No costs. Consequently, connected miscellaneous petition is closed.

¶36

(G.R.S. J.,) & (R.K.M. J.,) 11.12.2025 NCC : Yes/No Index : Yes / No Internet : Yes/ No ias

¶37

3/4

¶38

https://www.mhc.tn.gov.in/judis

¶39

W.A.(MD)No.1484 of 2022

¶40

G.R.SWAMINATHAN, J. and R.KALAIMATHI, J.

¶41

ias