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“The Entire Electoral College Itself Is Flawed”: Supreme Court Upholds Nullification of CSI Synod Elections and Directs Reconstitution by Court-Appointed Administrators

“The Entire Electoral College Itself Is Flawed”: Supreme Court Upholds Nullification of CSI Synod Elections and Directs Reconstitution by Court-Appointed Administrators

INTRODUCTION:
The Supreme Court of India Division Bench of Justice Sanjiv Khanna and Justice Dipankar Datta held that the elections conducted by the Church of South India Synod were vitiated due to fundamental irregularities in the formation of the electoral college. The Court affirmed the High Court’s direction declaring all elections of office bearers—including the Moderator—as invalid and upheld the appointment of a Committee of Administrators to oversee the conduct of fresh elections. The Court further directed that these elections be supervised independently in compliance with the Constitution of the Church of South India. The apex court’s ruling concluded multiple legal challenges concerning amendments to the Church's Constitution and alleged procedural improprieties in the Synod’s electoral process.

CASE DETAILS:
The case arose from a series of civil suits filed before the Madras High Court challenging the legitimacy of amendments passed during a Special Synod Meeting of the Church of South India (CSI) held on 7th and 8th March 2022. These suits also questioned the validity of the subsequent elections of office bearers conducted by the CSI Synod for the term 2023–2026.

The disputes centered on allegations that the Synod meeting had not been properly convened under the Constitution of CSI, and that the amendments passed therein—particularly concerning the retirement age of bishops and presbyters—were invalid. The plaintiffs contended that the amendments and the elections that followed were procedurally flawed and unconstitutional.

The four primary civil suits forming the foundation of the case were:

  1. C.S. No. 86 of 2022, filed on 03.01.2022, challenged the eligibility of certain individuals, including the then Moderator, to contest elections in light of their alleged criminal antecedents. The plaintiffs sought framing of a scheme under Section 92 of the Code of Civil Procedure (CPC) to prescribe qualifications and disqualifications for office bearers.
  2. C.S. No. 45 of 2022, filed on 01.03.2022, challenged the convening of the Special Synod Meeting itself, seeking a declaration that the notice and the meeting were invalid. The suit further sought an injunction restraining the implementation of any amendments passed during the meeting.
  3. C.S. No. 274 of 2022, filed on 20.12.2022, directly assailed the resolutions passed in the Special Synod Meeting of March 2022, particularly the amendment to increase the retirement age of bishops to 70 years. The plaintiff sought the appointment of a retired High Court judge as administrator to oversee the electoral process.
  4. C.S. No. 7 of 2023, filed on 02.01.2023, sought a declaration that the CSI notification dated 27.12.2022 ratifying the amendments was illegal and void. It prayed for injunctive relief against holding elections based on the impugned notification.

Interim reliefs were sought in all four suits. In C.S. No. 45 of 2022, the Single Judge of the Madras High Court granted interim injunction restraining the implementation of the resolutions passed in the Special Synod Meeting. The defendants, including senior office bearers of the CSI, challenged these interim orders through appeals.

The Single Judge, in a detailed interim order dated 05.09.2023, analyzed the procedural validity of the Special Synod Meeting and the manner in which the constitutional amendments were passed and ratified. He concluded that although the meeting appeared duly convened, the ratification of the amendments by diocesan councils was not in compliance with the constitutional requirements, rendering the amendments invalid. The Judge further ruled that the election of the Moderator was invalid due to its reliance on unconstitutional amendments, but allowed the results of the elections for the Deputy Moderator, General Secretary, and Treasurer to stand provisionally.

Appeals were filed against this order by both sides: those challenging the invalidation of amendments and those seeking wider invalidation of all office bearer elections.

The Division Bench of the High Court, in orders dated 27.02.2024 and 12.04.2024, ruled that the entire electoral college was flawed. It observed that the composition of the Synod did not adhere to the requirements regarding youth and women representation as prescribed by the CSI Constitution. Consequently, the Division Bench directed that the entire election process be nullified, and a Committee of Administrators be appointed to conduct fresh elections under court supervision.

The matter then reached the Supreme Court through Special Leave Petitions filed by various aggrieved office bearers and members of the Synod.

 

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