In Brief
The case concerns a dispute over property claimed by a religious trust (Kutchi Lal Rameshwar Ashram Trust) at Haridwar, which alleged that the property was purchased and held on its behalf through a disciple named Mohan Lal. After Mohan Lal disappeared in 1958, a third party complained to the Collector that the property should vest in the government under Section 29 of the Hindu Succession Act (escheat doctrine) due to lack of legal heirs. The Collector ordered vesting without following civil court procedures. The Supreme Court held that the Collector acted without jurisdiction: where title is disputed, only civil courts can adjudicate such matters. The state bears a heavy onus to prove complete failure of heirs, and such adjudication cannot be delegated to administrative officials. The Court allowed the appeal and quashed the Collector's order.
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