PARMANANDA MAHAPATRA vs COMMISSIONER OF HINDU RELIGIOUS ENDOWMENTS,ORISSA AND OTHE

The Supreme Court held that a suit under Section 64(2) of the Orissa Hindu Religious Endowment Act is not subject to the provisions of Order 1, Rule 8 of the Civil Procedure Code, as the Commissioner represents public interest and individual members of the public lack locus standi. The Court affirmed the High Court's decision that the suit was not maintainable due to the absence of public impleadment, thereby upholding the legality of the Commissioner's order declaring the temple a 'public excepted temple'.