MAHANT RAM SAROOP DASJI vs S. P. SAHI, SPECIAL OFFICER-IN-CHARGE OF THE HIN

The Supreme Court held that the Bihar Hindu Religious Trusts Act, 1950, specifically Section 2(1), does not apply to private trusts, distinguishing between public and private religious endowments. The Court found that the Salouna asthal, as a private institution, did not fall under the definition of a 'religious trust' as per the Act. Consequently, the order of the Bihar State Board of Religious Trusts requiring the appellant to submit a return of income and expenditure was quashed, affirming that private trusts are not governed by the provisions of the Act.