M. Siddiq Case (2019)

– Ayodhya Land Dispute

Background of the Case

The dispute concerned 2.77 acres of land in Ayodhya, where:

• The Babri Masjid stood until its demolition in 1992
• Hindus claimed the site as the birthplace of Lord Ram (Ram Janmabhoomi)

The litigation history spanned:

• More than a century
• Multiple civil suits
• Conflicting historical, archaeological, and religious claims

In 2010, the Allahabad High Court → Divided the land into three equal parts
→ Ram Lalla Virajman
→ Nirmohi Akhara
→ UP Sunni Central Waqf Board

All parties appealed to the Supreme Court.

Core Legal Questions

1. Who has better title to the disputed land under civil law?
2. How should courts adjudicate disputes involving faith and belief?
3. Can illegal acts (like the 1992 demolition) create legal rights?

Nature of the Case

The Supreme Court clarified that:

• This was not a criminal trial
• It was a civil suit based on title and possession
• Faith alone could not decide the outcome, but belief was relevant to possession

Supreme Court’s Judgement

A five-judge Constitution Bench, delivered a unanimous verdict.

(a) Entire Disputed Land Awarded to Ram Lalla Virajman

The Court held that:

• The deity Ram Lalla Virajman is a juristic person
• Hindu parties were able to establish:
  • Continuous worship
  • Long-standing belief that the site was Ram Janmabhoomi

Based on:

• Evidence of possession
• Archaeological findings (ASI report)
• Documentary and oral records

The Court awarded the entire 2.77 acres to Ram Lalla Virajman.

(b) Construction of Ram Mandir – Trust to Be Set Up

The Court directed that:

• The Central Government shall:
  • Formulate a scheme
  • Establish a trust
    • For construction of a Ram Mandir at the disputed site

(c) Alternative Land to Sunni Waqf Board

Acknowledging:

• The illegal demolition of Babri Masjid in 1992 and Violation of rule of law → The Court directed that:
• 5 acres of alternative land be allotted to → UP Sunni Central Waqf Board → At a prominent and suitable place in Ayodhya → For construction of a mosque

This was done as a measure of equitable justice, not title recognition.

(d) Nirmohi Akhara’s Claim Rejected

The Court held that:

• The suit by Nirmohi Akhara claiming shebaiti rights → was barred by limitation

Hence, the claim was dismissed

However:

• The Court directed that:
  • Appropriate representation may be given to the Akhara in the trust, as deemed fit by the Centre

Shebaiti rights refer to the legal and managerial rights of a person (called a shebait) who acts as the guardian, manager, and custodian of a Hindu deity’s property and worship

Key Constitutional and Legal Principles

• Rule of law must prevail over acts of force
• Illegal acts do not create legal rights
• Courts must:
  • Decide civil disputes on evidence
  • Maintain constitutional balance and harmony
• Faith is respected, but law is decisive

Impact of the Judgement

(a) End of a Century-Old Dispute

• The verdict finally settled:
  • A dispute that deeply affected communal harmony
  • Political and social stability

(b) Implementation of Directions

Following the judgment:

• The Centre constituted:
  • Shri Ram Janmabhoomi Teerth Kshetra Trust
• The UP Government:
  • Allotted 5 acres of land at Dhannipur, Ayodhya to the Sunni Waqf Board

(c) Allahabad High Court Verdict Overturned

• The Supreme Court:
  • Set aside the 2010 High Court judgement
  • Which had divided the land into three parts

Constitutional Significance

This judgment:

• Demonstrated judicial restraint and balance
• Reinforced → Secularism as equal respect for all religions
• Resolved a dispute through → Law, not politics
• Became a precedent in adjudicating faith-based civil disputes

Summary

The Ayodhya Case (2019) awarded the disputed land to Ram Lalla Virajman, directed the construction of a Ram Mandir through a trust, granted 5 acres of alternative land to the Sunni Waqf Board, and finally resolved a century-old civil dispute by upholding the rule of law and constitutional balance.