BIHAR STATE BOARD OF RELIGIOUS TRUST vs PALAT LALL AND ANOTHER

The Supreme Court held that the endowment created by the testator in favor of an idol was a private trust and not subject to the Bihar Hindu Religious Trusts Act, 1950. The Court found that the idol had been worshipped exclusively by the family and there was no evidence of public access or rights to worship. The Court dismissed the appeal, affirming the lower courts' findings that the arrangement was intended for family management rather than public benefit, and that tax exemptions claimed did not alter the nature of the trust.