S.P. Mittal vs Union of India (1983)

SC held Sri Aurobindo Society not a religious denomination; upheld Auroville Act, 1980 as valid and non-violative of fundamental rights.

S.P. Mittal vs Union of India (1983): Case Summary

Syllabus: Polity and Governance (UPSC GS II)

About:

In S.P. Mittal vs Union of India (1983) 1 SCR 729, the Supreme Court held that the Sri Aurobindo Society was not a religious denomination, and upheld the constitutional validity of the Auroville (Emergency Provisions) Act, 1980.

Facts of the Case

Sri Aurobindo, a philosopher and freedom fighter, founded an Ashram at Pondicherry.
His disciple, Madame Mirra Alfassa (The Mother), later guided the movement.
Followers established the Sri Aurobindo Society in 1960 to spread his philosophical teachings, distinct from the Aurobindo Ashram.
The Society developed Auroville, a township supported by national and international donations.
After The Mother’s death, allegations of mismanagement led the Union Government to assume control through an ordinance, later replaced by the Auroville (Emergency Provisions) Act, 1980.
The Act’s validity was challenged before the Supreme Court.

Issues Before the Court

Whether Parliament had the legislative competence to enact the Auroville (Emergency Provisions) Act, 1980?
Whether the Act violated Articles 14, 25, 26, 29, and 30 of the Constitution?

Supreme Court’s Findings

1. Legislative Competence:

The Act did not fall under Entry 32 of the State List (societies).
Parliament was competent to legislate under the residuary powers (Entry 97, List I).

2. Religious Denomination:

The Court referred to Shirur Mutt Case (1954 SCR 1005) and defined a religious denomination as one having:
(a) Common faith, (b) Common organization, and (c) Distinct name.
Based on the Society’s Memorandum and conduct, the Court held that Sri Aurobindo’s teachings were philosophical, not religious, and hence, the Society was not a religious denomination.

3. Articles 25 & 26:

Even if it were religious, the Act did not violate these rights as it only regulated secular management, not matters of faith.

4. Article 14:

The Act was not discriminatory. Due to Auroville’s unique international nature and public funding, Parliament could treat it as a distinct class.

Judgment

The Supreme Court upheld the validity of the Auroville (Emergency Provisions) Act, 1980.
It ruled that the Sri Aurobindo Society was not a religious denomination, and the Act did not infringe upon Articles 14, 25, or 26.