RADHAKANTA DEB & ANR. vs COMMISSIONER OF HINDU RELIGIOUS ENDOWMENTS, ORISSA

The Supreme Court established tests to determine whether an endowment is of a private or public nature, emphasizing that the origin of the endowment, control and management, and stipulations regarding public contributions are key factors. The Court held that in the present case, the endowment was private as evidenced by an ancient document indicating the founder's intention to install a family deity, with management retained by the founder's family. The judgment followed precedents including Deoki Nandan v. Murlidhar and Mahant Ram Saroop Dasji v. S.P. Sahi.