Kerala HC Suo Motu Impleads Nine Authorities Over Kottiyoor Temple Pilgrimage Conditions

A Division Bench found that environmental, forest, wildlife, and infrastructure concerns at Kottiyoor Temple require coordinated statutory action before the next festival season.

Although the writ petition in K.K.N. Kurup & Another v State of Kerala & Others had been reserved for judgment, a Division Bench of the Kerala High Court stepped back from deciding it and instead directed nine additional authorities to be impleaded. Justice Raja Vijayaraghavan V, leading the bench alongside Justice K.V. Jayakumar, concluded on 22 June 2026 that the issues raised — spanning environmental protection, forest conservation, wildlife management, public infrastructure, crowd regulation, and pilgrimage administration — required consideration by the relevant statutory bodies before the next festival season at the Kottiyoor Temple in Wayanad District. The bench tagged the matter with WP(C) No. 20262 of 2026 and listed it for 3 July 2026.

What the Petitioners Sought

The writ petition sought directions commanding the respondents to provide adequate public facilities for pilgrims attending the Kottiyoor Temple. The specific reliefs included rain-proof shelters, clean sanitation facilities, separate changing rooms for women, medical aid posts, safe drinking water, and proper pathways. The petitioners also sought measures to prevent overcrowding, stampedes, and similar incidents.

Beyond immediate amenities, the petition raised the absence of safe road access, adequate barricades, lighting, and sanitation. The petitioners further sought directions for the formulation and implementation of a comprehensive Master Plan for the holistic development of the Kottiyoor pilgrimage centre, covering sustainable infrastructure, crowd management, traffic regulation, parking facilities, and environmental protection.

The roads leading to the temple were described as poorly maintained and steep, making access difficult for elderly and differently-abled devotees. Parking was identified as a separate problem: thousands of vehicles, including buses and motorcycles, converge on the site without adequate facilities to accommodate them. The petition also raised concerns about insufficient space for Annadanam and consequent food safety and cleanliness issues.

The Temple, Its Setting, and the Existing Scheme

The Kottiyoor Temple sits within the forested terrain of Wayanad District, inside the Kottiyoor Wildlife Sanctuary, on the banks of the Bavali River. The bench noted that the temple complex occupies gently undulating terrain, with the lowest point at approximately 120–125 metres above sea level. The Ikkare shrine stands at 150–155 metres and the Akkare shrine at 135–140 metres, close to the river. The bench observed that any future development must account for this topography to ensure natural drainage patterns remain undisturbed.

The annual Vaishakha Mahotsavam, a 28-day festival held during May–June, is one of Kerala's most significant religious gatherings. During the 2024 festival season alone, footfall reached approximately 40 lakh devotees. Only temporary and simple structures are permitted at the Akkare shrine, and the temple is surrounded by an 80-acre sacred grove. Traditional materials — bamboo, timber, and thatch — are used for temporary shelters to ensure minimal ecological disturbance.

On the administrative side, the bench noted that a Coordinate Bench of the Kerala High Court had, in MFA No. 74 of 1988 and connected cases, framed a scheme for the administration of Sree Thricherummanna @ Kottiyoor Devaswom. That scheme came into force on 6 April 1994. Under it, administration, control, and management vest in a Board of Trustees comprising hereditary trustees, non-hereditary trustees, the Rajah of Kottayam or his nominee, and the President and Secretary of Sri Kottiyoor Perumal Seva Sanghom. Clause 21(i) of the scheme expressly bars the Chairman of the Board or the Executive Officer from interfering with religious or spiritual matters.

The area was previously governed by the Malabar Private Forest Act, 1948. The bench recorded that new laws now apply: the Wildlife (Protection) Act, 1972, the Forest (Conservation) Act, 1980, the Indian Forest Act, 1927, the Eco-Sensitive Zone (ESZ) Guidelines, 2011, issued by the Ministry of Environment, Forest and Climate Change, and the relevant guidelines of the Kerala Forest Department.

Challenges Identified on the Record

The bench identified several distinct challenges from the material before it. Traffic congestion on narrow roads during the 28-day festival creates logistical overload and adversely affects emergency access. The annual construction and dismantling of ritual structures at Akkare Kottiyoor using biodegradable materials is a labour-intensive exercise that must be repeated each year. Managing large pilgrim crowds and the consequent waste generation within the protected 80-acre sacred grove and the surrounding wildlife sanctuary presents environmental difficulties.

Because the festival coincides with the monsoon season, the safety of devotees crossing the Bavali River during heavy rains is a recurring concern. The bench also noted that scientific methods of waste management were not being adequately implemented despite the scale of the gathering. Coordination with numerous local communities holding traditional rights in relation to festival rituals and processions adds a further layer of complexity.

The NIT Report and Its Recommendations

The bench drew on a report by the National Institute of Technology on the Sustainable Development and Ecotourism Management of Kottiyoor. The report recommended that approximately 40 acres of unutilised Government land be used for parking facilities. It proposed temporary structures using local and reusable materials — bamboo, laterite, timber, and clay tiles — following sustainable and reversible design principles.

On sanitation, the report recommended bio-toilets and composting facilities. For river crossings during the monsoon, it proposed temporary rope bridges to ease movement and provide alternative crossing routes. On crowd management, the report suggested organised parking and vehicle drop-off zones on the periphery of the temple site, with separate zones for buses and larger vehicles. Temporary bamboo or timber fences for crowd regulation were also proposed. The report further recommended the introduction of a virtual queue system and an assessment of the carrying capacity of the temple.

Why the Bench Declined to Decide and Chose Impleadment

The Division Bench had reserved the matter for judgment but, on reconsideration of the averments in the writ petition, the counter affidavit filed by the respondents, and the facts and circumstances, concluded that “the matter requires deeper consideration.” The bench characterised the issues as cutting across environmental protection, forest conservation, wildlife management, public infrastructure, crowd regulation, and pilgrimage administration — areas that require the relevant statutory authorities to be heard and to provide their inputs before any directions are issued.

Rather than proceed to a final order without those authorities on record, the bench exercised its power to suo motu implead nine additional respondents. The rationale was that the issues needed to be addressed before the ensuing festival season, making early and coordinated engagement by the statutory bodies necessary.

Outcome

The bench directed the Registry to carry out the impleadment of the following nine additional respondents:

• Union of India, through the Secretary, Ministry of Environment, Forest and Climate Change, New Delhi (Addl. R6);
• Principal Chief Conservator of Forests & Head of Forest Force, Thiruvananthapuram (Addl. R7);
• Chief Wildlife Warden, Thiruvananthapuram (Addl. R8);
• Conservator of Forests, Northern Circle, Kannur (Addl. R9);
• Divisional Forest Officer, Kannur Forest Division (Addl. R10);
• Director, Kottiyoor Wildlife Sanctuary, Kannur District (Addl. R11);
• Kerala State Pollution Control Board, represented by its Member Secretary, Thiruvananthapuram (Addl. R12);
• Secretary, Local Self Government Department, Thiruvananthapuram (Addl. R13);
• Secretary, Kottiyoor Grama Panchayat, Kannur District (Addl. R14).

The learned Additional Solicitor General of India was directed to take notice for the MoEFCC. The Government Pleader was directed to take notice for additional respondents 7 to 11 and 13. The Standing Counsel was directed to take notice for additional respondent 12. Notice to the Secretary, Kottiyoor Grama Panchayat, was directed to be issued by Speed Post.

The ASGI, the Government Pleader, and the Standing Counsel were directed to obtain instructions from their respective respondents regarding measures that may be adopted to address the issues faced at the temple. The matter was tagged with WP(C) No. 20262 of 2026 and posted for hearing on 3 July 2026.