J&K High Court Flags Infighting in Jammu’s Gurdwara Committee, Demands Affidavits on Gurdwara Accounts and Administration
Justice Rahul Bharti found elected office-bearers of District Gurdwara Prabhandhak Committee Jammu locked in factional litigation, directed affidavits on Gurdwara administration and audit, and suo motu impleaded two sidelined elected members.
Justice Rahul Bharti, sitting singly at the Jammu bench of the High Court of Jammu & Kashmir and Ladakh, took a sharply interventionist course on 7 September 2026 in a petition filed under Article 227 of the Constitution. The petition — CM(M) No. 319/2025 — arose from a civil suit in which two elected office-bearers of the District Gurdwara Prabhandhak Committee (DGPC), Jammu were challenging decisions made by their own Committee’s elected President and a Member regarding the local administration of Gurdwara Chatti Pathshahi, Talab Tillo, Jammu. Rather than simply deciding which lower court order to restore, the bench directed all principal parties to file individual affidavits disclosing how many Gurdwaras in Jammu district are directly administered by the Committee and whether their accounts have been annually audited. The Committee’s elected Treasurer and Joint Secretary, conspicuously absent from the suit, were suo motu impleaded as respondents.
The Dispute That Reached the High Court
The District Gurdwara Prabhandhak Committee, Jammu was constituted through elections held in June 2022. The elected office-bearers are: S. Ranjeet Singh Tohra (President), S. Balvinder Singh (Vice-President), S. Surjeet Singh (Secretary), S. Ranvir Singh (Joint Secretary), and S. Jagpal Singh (Treasurer), along with other elected members including S. Karan Singh Bali.
On 3 May 2025, the President, Ranjeet Singh Tohra, issued letter No. DGPCJ/077/2025 authorising Member Karan Singh Bali to appoint and announce a local committee for Gurdwara Chatti Pathshahi, Talab Tillo, Jammu. Acting on that authority, Karan Singh Bali issued letter No. 22/2025 dated 5 May 2025 appointing Sardarni Harpreet Kour as President and S. Manmohan Singh as Secretary of the local committee of that Gurdwara.
On 6 May 2025, the Vice-President and Secretary — S. Balvinder Singh and S. Surjeet Singh — filed Civil Suit No. 820/2025 before the Sub-Judge, Jammu, ostensibly in the name of the DGPC itself. They sought declarations that both letters were null and void, and a permanent prohibitory injunction restraining Harpreet Kour and Manmohan Singh from acting in their appointed capacities. On the very day of filing, the Sub-Judge granted an ad interim ex parte stay of both communications.
On 30 June 2025, the Sub-Judge made that ad interim direction absolute, converting it into a full temporary injunction under Order 39 Rules 1 and 2 of the Code of Civil Procedure, 1908. The defendants — the President and Member — then filed Civil Misc. Appeal No. 115/2025 before the Additional District Judge, Jammu. That court went the other way: it dismissed the plaintiffs’ temporary injunction application entirely, reversing the Sub-Judge. The plaintiffs, aggrieved by that reversal, approached the High Court under Article 227.
The Statutory Framework Under Examination
The Jammu & Kashmir Sikh Gurdwaras and Religious Endowment Act, 1973 continues to operate in the Union Territory of Jammu & Kashmir by virtue of the Jammu & Kashmir Reorganisation Act, 2019, the 1973 Act appearing at serial No. 147 in the Fifth Schedule (Table-4) read with section 95(2) of the 2019 Act.
Section 10 of the 1973 Act provides for the constitution of a Prabhandhak Committee for one or more districts for the administration and management of Sikh Gurdwaras. Section 11 governs the composition of district-wise committees; Section 13 prescribes members’ terms; and Section 14 confers on a Committee “full powers of control over the office holders and all properties and income of whatever description belonging to the Gurdwara or Gurdwaras under its management.”
Section 3 of the Act provides for the UT-level Sikh Gurdwara Prabhandhak Board, which holds overarching superintendence over the district committees. Rule 63(b) of the Jammu & Kashmir Sikh Gurdwaras and Religious Endowment Rules, 1975 empowers the Board to suspend or remove a District Gurdwara Prabhandhak Committee. Rule 58 vests staff appointment power in the President subject to Committee confirmation. Rules 61 and 62 govern Gurdwara funds and receipts; Rule 63 governs accounts maintenance.
Justice Bharti identified the core legal question as whether Section 14 read with Section 10 permits a District Committee to constitute Gurdwara-level local administrative bodies, and if so, by what modality. That question remained unanswered at the level of both lower courts, which had confined themselves to the injunction dispute.
How the Bench Reasoned
The bench was frank in its assessment. It found that both sets of litigants — the plaintiffs seeking restoration of the Sub-Judge’s order and the defendants seeking to preserve the Additional District Judge’s order — were treating the petition as a vehicle for factional advantage rather than for the welfare of Sikh Gurdwaras or the Sikh Sangat of Jammu district. The bench described the scenario as “fence trying to eat the crop.”
Justice Bharti observed that S. Jagpal Singh (Treasurer) and S. Ranvir Singh (Joint Secretary), both elected members, had been left entirely out of the civil suit, as though the Committee were “a personal fiefdom of the two petitioners as plaintiffs and respondents as defendants.” Their absence from litigation affecting Committee governance was itself a red flag.
The bench noted that the present Committee has been in existence since 2022 for a five-year term, leaving over one year but less than two years before it demits office. In that remaining period, the infighting risked allowing office-bearers to use their respective positions to tighten or loosen control over individual Gurdwaras and their funds without accountability.
A pointed observation went to the institutional gap: had a duly constituted UT-level Sikh Gurdwara Prabhandhak Board been in place, it could have exercised its overarching jurisdiction to bring the Committee to course correction, including through suspension or removal. The civil suit, the bench reasoned, ought not to have needed to exist if that supervisory architecture had been functioning.
From a reading of the plaint, the written statement, the memo of appeal, and the petition before it, the court recorded a firm view that both sides were resorting — “be it by default or design” — to misrepresentation and a selective presentation of facts. The bench therefore decided that before adjudicating the petition or the injunction dispute, it needed the true state of DGPC administration placed on record.
The bench also flagged that if the appointment of local administrators for Gurdwara Chatti Pathshahi were an isolated act, it would raise one set of questions; if it turned out to be a pattern across multiple Gurdwaras in Jammu district — with administrators operating without accountability to the DGPC — the legal and governance picture would be materially different.
Directions Issued
Justice Bharti issued the following specific directions by order dated 7 September 2026:
Affidavit on Gurdwara administration: Both petitioners (the Vice-President and Secretary) and Respondent No. 1 (the President) are each directed to file an individual affidavit disclosing how many Gurdwaras in Jammu district are under the direct administration and management of the DGPC Jammu — without any locally elected, established, or set-up body — and how the DGPC directly manages those Gurdwaras through its office-bearers and elected members without any intervening body.
Affidavit on accounts and audit: Petitioner No. 2, S. Surjeet Singh (Secretary, DGPC Jammu), is separately directed to file an affidavit stating whether donations — in cash or kind — in respect of each and every Gurdwara in Jammu district have been subjected to annual audit, and to place audited statements of accounts of each Gurdwara and of the DGPC itself before the court at the next hearing.
Suo motu impleadment: S. Jagpal Singh, elected Treasurer, and S. Ranvir Singh, elected Joint Secretary, are suo motu impleaded as party respondents. Notices are to issue for their appearance, in person or through counsel. The petitioners are directed to furnish registered postal covers for service on the newly impleaded respondents.
Production of lower court records: Records of Civil Suit No. 820/2025 and Civil Appeal No. 115/2025 are to be called from the court of the Additional District Judge, Jammu.
All affidavits are to be filed on or before 5 October 2026. The bench recorded its intention to dispose of not only the present petition but also the civil suit itself, on the principle that litigation embroiling the administration of religious places among factions must be curbed in the larger interest of devotees and the Sangat.
Outcome
CM(M) No. 319/2025 was listed for further hearing on 5 October 2026. No interim relief was granted or vacated at this stage. The matter was reserved after hearing arguments on admission. The bench has directed individual affidavits from the Vice-President, Secretary, and President of DGPC Jammu, and has suo motu brought in the Treasurer and Joint Secretary as respondents. The civil suit records and the records of the appellate proceedings before the Additional District Judge, Jammu, are to be placed before the High Court.