THAKUR JANKI BALLABHJI MAHARAJ & ANR. vs THAKUR JANKI BALLABHJI MAHARAJ & ANR.

The Supreme Court held that Section 92 of the Code of Civil Procedure does not apply to suits filed by deities against individuals in management of temple properties, thus no prior sanction is required. The Court found sufficient evidence of mismanagement and misappropriation by the defendant, leading to the conclusion that he was unfit to manage the temple. The Court also affirmed its jurisdiction under Order 41 Rule 33 to frame a management scheme for the temple, even if it is not a public trust, thereby dismissing the defendant's appeal.