‘Well Orchestrated’: Allahabad High Court Slams UP Govt Over Unpaid Rs 1.21 Crore For Ayodhya Temple Land

The Uttar Pradesh government took possession of 1,512 sq metres of temple land in Ayodhya after executing a sale deed and promising to pay for it within 15 days. But the temple was still waiting for Rs 1.21 crore towards the land more than two years later, prompting the Allahabad High Court to direct the State to deposit the amount with 8% interest.

The land is situated at Sugriv Kila, adjacent to the Ram Janmabhoomi temple, and the temple's case was that the authorities had sought it for development works related to the temple.

A Bench of Justices Shekhar B. Saraf and Abdhesh Kumar Chaudhary was hearing a petition filed by Shri Thakur Ram Janki Sugrivji Virajman Mandir, situated at Sugriv Kila, Ayodhya.

Why was the temple not paid the full sale consideration?

The dispute concerns 1,512 sq metres in Khata No. 44/2, Khasra No. 246. According to the temple, the property had been recorded in the name of the deity in successive revenue settlements, despite changes in plot numbers.

The authorities and the temple entered into an MOU after negotiations over the cost of the land and construction. A sale deed was then executed on December 22, 2023. The total sale consideration was fixed at Rs 1,38,44,559, comprising Rs 1,20,96,000 towards the land and Rs 17,48,559 towards construction.

The temple's counsel told the court that although the entire sale consideration was payable, the authorities assured the temple that the amount would be transferred through RTGS within 15 days. The bank account number and IFSC code of the temple were also mentioned in the sale deed.

Relying on the assurance, the temple handed over possession of the land. Court noted that the sale deed was registered at 9 pm on December 22, 2023, and possession was taken immediately. However, the promised payment was not made within 15 days.

What was the State's defence?

The State did not dispute the agreed total sale consideration. It said the construction component of Rs 17,48,559 had already been paid, but argued that the remaining Rs 1,20,96,000 was not payable because the land was allegedly Nazul land belonging to the government.

The State also questioned the authority of the Sarvarahkar to sell the temple property. It said that since the title itself was disputed, it had filed a civil suit seeking cancellation of the December 22, 2023 sale deed. The suit is pending before the Additional Chief Judge-II (Junior Division).

Why did the high court question the State's conduct?

The bench said there was no dispute that a sale deed had been executed and that the Rs 1,20,96,000 land component remained unpaid.

Court found it “rather amusing” that the State was disputing the title to avoid paying the consideration while continuing to remain in possession of the property. If the State was not convinced about the temple's ownership, court said, the property ought to have been returned to the temple. The authorities' continued possession and subsequent filing of a suit for cancellation of the sale deed “speak volumes” about their conduct.

The bench further said the conduct of the authorities could not be termed “fair, proper or reasonable”. It observed that the authorities appeared to have “fooled” the petitioner into giving up possession of the land through the sale deed and then “volte-faced” by claiming that it was Nazul or government land and could not have been sold.

“The whole story seems to be well orchestrated,” court said, observing that the conduct appeared aimed at taking possession “in a jiffy” and subsequently denying the legitimate payment.

What did the court say about the title dispute?

The high court made clear that it was not deciding who owns the disputed land.

It said the title issue could not be adjudicated in the writ proceedings without allowing the parties to lead evidence in a full-fledged trial. That question would therefore have to be decided by the civil court where the State's suit is already pending.

The bench also observed that payment of the entire sale price at the time of execution of a sale deed is not an essential condition for completion of a sale. Non-payment of the balance consideration does not invalidate a registered sale deed, and the remedy is to recover the unpaid amount.

What did the court order?

Since a civil suit was already pending, the high court directed the State to deposit the outstanding sale consideration along with 8% annual interest, calculated from the expiry of the 15 days promised for payment.

The amount has to be deposited within four weeks in an interest-bearing fixed deposit in a nationalised bank in the name of the Additional Chief Judge-II (Junior Division), where the civil suit is pending. The trial court will decide whether to release part or all of the amount, including accrued interest, to the temple depending on the circumstances and the outcome of the suit.

The high court also directed that the civil suit concerning the 2023 sale deed be expedited and that efforts be made to conclude the trial, preferably within one year.

The bench clarified that it had only examined the conduct surrounding the execution of the sale deed and taking of possession and had not adjudicated the title. Both sides remain free to produce their documents and witnesses before the civil court, with all questions of law left open.

Case Title: Shri Thakur Ram Janki Sugrivji Virajman Mandir, Thru. Sarvarahkar Swami Vishvesh Prapannacharya v. State of U.P. Thru. Prin. Secy. Public Works Deptt. Lko. & 5 Others

Order Date: August 11, 2026

Bench: Justice Shekhar B. Saraf and Justice Abdhesh Kumar Chaudhary