Bhojshala Case: Architectural Evidence Placed Before Madhya Pradesh High Court Pointing To Pre-Existing Temple

The Madhya Pradesh High Court at Indore on Wednesday continued hearing in the Bhojshala dispute, with advocate Manish Gupta advancing arguments in a connected writ petition, Kuldeep Tiwari v. Union of India Ministry of Culture, seeking to reinforce the claim that the disputed structure was originally a temple and a centre of Sanskrit learning established during the Paramara period.

Appearing before a division bench of Justice Vijay Kumar Shukla and Justice Alok Awasthi, Gupta built upon earlier submissions to argue that literary, epigraphic and architectural materials consistently indicate a pre-existing temple complex.

At the outset, Gupta referred to historical texts and gazetteers to submit that Dhar was a prominent centre of Sanskrit scholarship under Raja Bhoj, attracting Hindu, Jain and Buddhist scholars.

He argued that multiple sources record that the structure, originally a temple and learning centre, was later converted into a mosque, with inscriptions and architectural remnants continuing to reflect its earlier character. He relied on references to “Sarvabandhi” inscriptions and large stone slabs found at the site, submitting that such inscriptions were pedagogical tools used to teach Sanskrit grammar.

The bench engaged with the material, particularly on the existence of inscriptions and the Saraswati idol. When queried on documentary proof, Gupta pointed to an inscription on the pedestal of an idol of Vagdevi Saraswati, now housed in the British Museum. Reading from compiled material, he submitted that the inscription records that the idol was “prasthapitam,” indicating formal consecration during the reign of Raja Bhoj. “The image was properly consecrated in the temple,” he argued, relying on ASI publications and epigraphic records.

Gupta then placed reliance on the Supreme Court’s Ayodhya judgment to explain the evidentiary value of historical texts and gazetteers. Citing passages, he submitted that while such materials may not conclusively determine title, they are relevant as corroborative evidence. “The court may resort to books and documents on matters of public history,” he argued, emphasising that these sources collectively support the temple origin narrative.

A substantial portion of the arguments focused on architectural analysis drawn from the Samarangana Sutradhara, an 11th-century treatise attributed to Raja Bhoj. Gupta argued that the structural features described in the text correspond closely with the existing layout of the Bhojshala complex. He highlighted prescriptions relating to temple construction, including central Vedic platforms, orientation along cardinal directions, and proportional measurements.

Drawing the court’s attention to the ASI survey reports, Gupta submitted that a central brick structure identified as a “vedi” or havan kund matches the specifications described in the treatise. He argued that the dimensions of the structure correspond to traditional measurements, stating that “this havan kund… corresponds to the prescriptions given in the text.” He further pointed out that bricks used in the central structure and the foundation were sourced from the same kiln, indicating a unified, original construction.

The bench sought clarification on the relevance of architectural texts, observing that Gupta’s attempt was to correlate the physical features of the site with historical architectural norms. Acknowledging this, Gupta clarified that his submissions were intended as corroborative. “Comparison reflects what the character of the building may be,” he stated, adding that similarities with other Paramara-era temples further support the claim.

He also relied on comparative analysis with temples such as the Udayeshwar temple, arguing that features like east-facing orientation, mandapa structures, and sculptural elements align with known temple architecture. Gupta submitted that “all these facts… establish that this is a temple,” reiterating that the structure was built in accordance with the architectural prescriptions of the period.

The court noted that the submissions were aimed at supplementing earlier arguments with additional material. “You want to corroborate… that whatever has been found… corresponds to the architecture prevailing at the relevant time,” the bench observed.

The hearing remained focused on whether the cumulative historical, epigraphic and architectural evidence can establish the original character of the site. The matter will continue for further arguments.

Case Title: Hindu Front for Justice (Regd. Trust No. 976) Through its President Ms. Ranjana Agnihotri v. Union of India Ministry of Culture and other connected matters

Date of Hearing: April 15, 2026

Bench: Justice Vijay Kumar Shukla and Justice Alok Awasthi