FICTION
M. Siddiq (D) Thr. Lrs. v. Mahant Suresh Das & Ors. (Ayodhya)
(2020) 1 SCC 1 (Supreme Court of India, 9 November 2019) · 2019
An idol of an infant deity received title to 2.77 acres of disputed land — as a juridical person in his own right.
“An idol consecrated and installed at a public place for public at large becomes a juristic entity capable of holding property and being a party to legal proceedings.”
The Ruling
A five-judge bench of the Supreme Court of India unanimously awarded the disputed Ayodhya site to Ram Lalla Virajman — the infant form of the deity Ram, recognised as a juristic person and named litigant in the proceedings. The Court held that 'God or Supreme Being' is not itself a juristic personality, but that 'an idol, worshipped by believers as a physical incarnation of the God, can be considered a juridical personality' once consecrated and installed for public worship. The line of authority extends back through Shiromani Gurdwara Parbandhak Committee v. Som Nath Dass (2000) and Bishwanath v. Shri Thakur Radhaballabhji (1967).
The Personhood Argument Not Made
This is the doctrinal precedent that makes the Indian river cases possible. Hindu juristic-person doctrine has, for over a century, recognised consecrated idols as persons capable of holding property, suing, and being sued. When the Uttarakhand High Court extended the doctrine to the Ganga and Yamuna in 2017, it was reaching not into novel territory but into a well-developed indigenous legal apparatus for personhood beyond the human-corporate binary. Ram Lalla is the closest the world has yet come to formal personhood for a non-natural, non-corporate, non-human entity — and the closest existing answer to the question 'could a bridge be a person?' The answer in Indian law is: only if it is consecrated, only if it is worshipped, and only if a guardian comes forward.
The Execution Gap Created
Ram Lalla won the land. The doctrinal reach of the precedent — whether it can be deployed for entities outside the religious frame — has not been tested. No Indian court has yet recognised a non-religious constructed entity as a juristic person on the deity model. The doctrine exists; its secular extension does not.
Primary sources & research
Related cases
Part of The Personhood Prism, the companion to The Execution Gap by Thomas William Hornig. See all personhood cases →