Court caseAIR 2000 SC 1421

Land in a village in Punjab stood recorded in the revenue records in the name of the Guru Granth Sahib installed in a gurdwara. In proceedings under the Sikh Gurdwaras Act, 1925 the question arose whether the property belonged to the gurdwara (and so came under the management of the SGPC) or to the persons in possession. The High Court held that the Guru Granth Sahib was not a juristic person and so could not own the land. The SGPC appealed.

Misra J explained that a juristic person is an entity to which the law attributes personality because that serves a social or legal need; the concept grew with the needs of society and is not confined to idols. The Guru Granth Sahib is not merely a sacred book: after Guru Gobind Singh it has been installed in gurdwaras and revered as the eternal living Guru, worship is offered to it, and property is dedicated to it. It therefore has the attributes of a juristic person and can hold the property recorded in its name. The court was careful to add that not every copy of the Granth in every home is a juristic person; only the Guru Granth Sahib installed in a gurdwara as the object of worship. The appeal was allowed.