IN THE HIGH COURT OF JUDICATURE AT MADRAS (Special Original Jurisdiction) W.P. No. _______________ of 2025 Rangarajan Narasimhan M/55 Sanathana Dharmam/Sri Vaishnavam “Arangan Thirumutram” Kollidam Road 400m west of Andavan Ashramam Srirangam, Trichy – 620 006 …Petitioner Versus 1. The Director General of Police

IN THE HIGH COURT OF JUDICATURE AT MADRAS
(Special Original Jurisdiction)
W.P. No. _______________ of 2025

Rangarajan Narasimhan M/55
Sanathana Dharmam/Sri Vaishnavam
“Arangan Thirumutram” Kollidam Road
400m west of Andavan Ashramam
Srirangam, Trichy – 620 006
…Petitioner Versus
1. The Director General of Police
Tamil Nadu Police Department
Dr. Radhakrishnan Salai, Mylapore,
Chennai-600 004
2. The Inspector General of Police Idol Wing CID
Police Training College No.2,
Natesan Salai, Ashok Nagar, Chennai – 600 083
3. The Deputy Superintendent of Police
Idol Wing CID
Police Training College No.2,
Natesan Salai, Ashok Nagar, Chennai – 600 083
4. The Station House Officer/Inspector of Police
Idol Wing CID
Police Training College No.2,
Natesan Salai, Ashok Nagar,
Chennai – 600 083
… Respondents
AFFIDAVIT OF RANGARAJAN NARASIMHAN
I, Rangarajan Narasimhan, Sanathana Dharma, Sri Vaishnavam, aged about 55 years, son of Shri P. R. Narasimhan, residing at “Arangan Thirumutram”, Kollidam Road, 400m west of Andavan Ashramam, Srirangam, Trichy – 620 006, now temporarily come down to Chennai, do hereby solemnly affirm and sincerely state as follows:
1) I am a person deeply interested in the preservation of the sanctity of Sanathana Dharma religions and religious institutions and to preserve the glory of the great Indian Heritage, Culture, Monuments, Practice, and related objectives.
2) I am also a person who is deeply interested in protecting and upholding the Law of the land and to strive to ensure that Fundamental Rights guaranteed by the Constitution of India is preserved and protected.
3) I respectfully submit that I have filed a number of public interest litigation petitions espousing the cause where the rights and sentiments of followers of Sanathana Dharma Religion grouped under the umbrella of Hinduism are being trampled upon by governmental action or inaction in contravention to Article 25, 26 and 27 of the Constitution of India.
4) I am a person who strives to leave no stone unturned to bring to the knowledge of the Temple of Justice the information that is required which are crucial to delivering Justice. Several orders of this Hon’ble Court had lauded my efforts in providing timely and just information and correct solution to this Hon’ble Court.
5) I submit that the details contained in the affidavit have been collated out of my own self acts and from the enquiries made with the concerned departments, Bhaktas, and citizens. I am an income tax assesse and my Permanent Account Number is AEGPR8372E. My annual income is about Rs. 2,50,000/-. My Aadhar Number is 6928 4841 9368. I hereby undertake to pay any cost that may be awarded if this Writ Petition is found to be frivolous. I am filing this Writ Petition as Public Interest Litigation.
6) I submit that I am very well aware of the facts and circumstances of the case.
SHRI DEVARAJA SWAMY TEMPLE, KANCHEEPURAM
7) I submit that Shri Devaraja Swamy Temple, Kancheepuram is a renowned Tempe of Sriman Narayana is noted alike for its historic and religious importance.
8) I submit Shri Devaraja Swamy Temple, Kancheepuram, hereinafter referred to as the Temple, is situated in Little Kancheepuram and is one of the 108 Divya Desams of Sri Vaishnava Sampradhaya. The temple is also called Hasthigiri
(as it is located on a small hillock), is a temple dedicated to Sriman Narayana.
Swamy Ramanuja, who was born in Sriperumbudur a few miles from the Temple, one of the greatest Sri Vaishnava Acharya had performed his Kainkaryam (holy selfless service to Lord as a Servant) in this temple.
9) I submit that the Temple is also called as “Perumal Koil”, and is considered to be one of the three holiest Sri Vaishnava Divya Desams, the other two being Koil (Srirangam) and Thirumalai (Tirupati).
10) I submit that the temple is governed by Padma Samhita of Sri Pancharatra
Agama Shastra. The Temple is a Denominational Temple belonging to Sri Vaishnava Sampradhaya (religious denomination) and is protected by Article 26 of the Constitution of India.
11) I submit that the Temple is governed by a scheme settled by Appeal No. 175 of 1934 on 17.01.1941 by this Hon’ble High Court, filed against the decree of the District Court of Chengalpattu in O.S. 1 of 1928.
12) I submit that as per the scheme, the Hon’ble Division Bench comprising of Justice Wordsworth and Justice Patanjali Sastri, the temple is required to be administered by a paid Executive Trustee, and two honorary trustees. Extract from the scheme is reproduced below for ready reference:
3. The Devasthanam shall be administered by a paid executive trustee, who shall be appointed by the Board and by two honourary trustees, who shall be elected in the manner laid down hereafter.
4. No person shall be appointed as executive trustee unless he is
1. A Smartha or Madhwa Brahmin
2. Aged not less than 30 years and not more than 62 years on the date of appointment
3. Willing to reside permanently in Conjeeveram for the period of his office.
5. The person appointed as executive trustee shall hold office for five years, subject to good conduct. He shall give security for a sum of Rs. 2000 to the satisfaction of the Board within one month of his appointment. He shall be paid such honorarium as the Board may determine which shall not exceed Rs. 100 per mensem.
6. The functions and powers of the trustee under the Madras Hindu Religious Endowments Act shall ordinarily be exercised by the executive trustee alone.
7. Of the two honorary trustees, one shall be a member of the eastern branch and the other of the western branch of the family of Koti Kenyakadenam Sri Thathadesikar.
13) I submit that this scheme is in vogue till date.
THE ANTIQUE IDOL OF LIZARDS, SUN AND MOON
14) I submit that inside the Temple, there is a idol of a lizard in the prakara behind Garbhagriha. The idol consists of a large lizard with Golden Kavacham, a small lizard with Silver Kavacham, the images of Sun and Moon, both covered with Golden Kavacham, all of them hosted on a wooden plank. This idol is there for several centuries in this Temple, and it is not known when the Golden and Silver Kavacham were adorned on the Lizard. Hereinafter this group of golden and silver lizards, the sun and moon idols are referred to as the antique lizard idol.
15) I submit that the entire area where this “golden lizard” is present inside the Temple, is covered with unsightly plywood partition by
(i) the Assistant Commissioner/Executive Trustee of the Temple, who is an employee of the HR&CE Dept (ii) the Honorary Trustees of the Temple,
collectively hereinafter referred to as the Temple officials, thereby marring the natural beauty of the Temple, in such a way that no one can have even a glimpse of what is inside the plywood partition, away from the direct sight of any devotee.
16) I submit that according to Kanchi Mahathmya in Brahmanda Purana, Chapter 31, Slokas 30 – 97, describes the story of a an Ikshvaku Kula Vamsa King, who ruled Ayodhya by name Asamanjas who got to be born in a low life with his wife for the heinous sins he had committed. Asamanjas and his wife were to be born in several low lives for t6 births and was born as a lizard in his 7th birth. These lizards (Asamanjas and his wife) attained Moksha when a Brahmin, Upamanyu, took great pity on them, strived hard to help them to get rid of their low birth and to attain Moksha. On the advice of Markandeya Maharishi, he carried them to Kanchipuram, where they attained Moksha.

17) I submit that having felt very happy, Upamanyu sang Stotrams on Shri Varadharaja Swamy. Pleased by the kind heart of Upamanyu, Shri Varadharaja Swamy said, “Let these golden bodies of the lizards be in my Sannidhi. When those who as per shastras have darshan and do Prathakshina to me and touch these golden lizards, they will be rid of all kinds of illness”.
This boon, even though many do not even know this story has been passed over several Yugas and several throngs to the Temple to have Darshan of Shri Varadharaja Swamy and touch the lizards to get rid of their illness.
18) There is a board displayed stating this story in a crude form that can be seen displayed at the Southwest corner of the Hasthigiri (The hill on which Shri Devaraja Swamy resides). Even yesterday, the board exists in the said place, and a picture of the board is presented below.
ATTEMPT TO STEALTHILY REMOVE THE ANTIQUE IDOL WITH MODERN REPLICA
19) I submit that Temple officials are attempting to replace the antique lizard idol with a modern replica without any authority whatsoever against the laws of the land.
20) I submit that the law of the land prohibits anyone from removing or replacing antique artefacts. The Management and Preservation of Properties of Religious Institutions Rules, hereinafter referred to as the MPPRI Rules, of the Hindu Religious and Charitable Endowments Act, 1959, hereinafter referred to as the HR&CE Act clearly prevents anyone from removing or replacing antique artefacts.
21) I submit that Rule 31 of the MPPRI Rules of the HR&CE Act states
31. Repairs, alterations, etc., to antiquities. – (1) A trustee or the Board of Trustees, as the case maybe, shall not repair, alter, replace, sell, gift away, or destroy any antiquities or other objects of interest such as sculptures, carvings, inscriptions or paintings without the written permission of the Commissioner and such permission shall be granted only on obtaining competent advice thereon.
(2) While granting permission under sub-rule (1), the Commissioner shall issue such instructions to the trustee or the Board of Trustees, as may be necessary, for preservation of works of art, sculpture, paintings, antiquities and other articles of interest and the trustees shall be bound to carry out such instructions.
22) I submit that Rule 52 of the MPPRI Rules of the HR&CE Act states
52. Alterations to or melting of idols. – No trustee or the Board of Trustees shall alter the character of or repair, remove, melt or replace any metallic or other idol or image in the temple, whether fixed or otherwise, without the express permission of the Government in writing.
23) I submit thus that it is amply clear that no antique artefact in a Temple can be replaced by Temple officials, or by anyone, for that matter.
24) I submit that the Temple officials, in collusion with the Archakas and other Temple employees, have made a brand new replica lizard of the antique lizard idol and are intending to replace the same stealthily. Below is the picture of the modern replica:

25) I submit that the antique idol is already been removed from its existing place by the Temple officials. There is no provision either in the Agama Shastras which govern the rituals of the Temple or the HR&CE Act or any other act of our great Nation.
26) I submit that the fact that the Temple officials having moved the antique lizard idol from its original position itself amounts to an attempted theft.
27) I submit that S.29(f) of the HR&CE Act requires that the HR&CE Dept, must maintain a register with inventory of all idols in the Temple.
29. Preparation of register for all institutions. – (1) For every religious institution, there shall be prepared and maintained a register in such form as the Commissioner may direct showing –
(a) the origin and history of the institution and the names of past and present trustees and particulars as to the custom, if any, regarding succession to the office of trustee;
(b) particulars of the scheme of administration and of the dittam or scale of expenditure;
(c) the names of all offices to which any salary, emolument or perquisite is attached and the nature, time and conditions of service in each case;
(d) the jewels, gold, silver, precious stones, vessels and utensils and other movables belonging to the institution, with their weights and estimated value
(e) particulars of all other endowments of the institution and of all title- deeds and other documents;

(f) particulars of the idols and other images in or connected with the institution, whether intended for worship or for being carried in processions;
(g) particulars of ancient or historical records with their contents in brief;
(h) such other particulars as may be required by the Commissioner.
28) I submit that S. 30 of the HR&CE Act requires that these registers be verified annually
30. Annual verification of the register.—The trustee or his authorized agent shall scrutinize the entries in the register every year and submit to 5[the Commissioner for his approval, directly or through the Assistant Commissioner], as the case may require; a verified statement showing the alterations, omissions, or additions, required in the register and the provisions of sub-section (3) to (6) of section 29 shall apply in relation to such statement as they apply in relation to a register.
29) I submit that S. 31 of the HR&CE Act requires that the registers must be submitted to the appropriate authorities every ten years
31. Submission of register once in ten years.—The Trustee or his authorized agent shall submit to 1[the Commissioner for his approval directly or through the Assistant Commissioner], as the case may require, once in every ten years (commencing from the year in which the register required under section 29 is first submitted), a consolidated register incorporating therein all alterations, omissions and additions made or required to be made in the register submitted under section 29 and the provisions of that section shall apply to such consolidated register as if it were a register submitted under that section.
30) I submit that the details of the antique lizard idol must be recorded by the HR&CE Dept.
31) I submit that furthermore, these antiquities are to be registered with the Archaeological Survey of India as well and therefore they must also have a record of these idols.
32) I submit that the Antiquities and Art Treasure Act, 1972, hereinafter referred to as the AAT Act is enacted to prevent smuggling of antiquities.
33) I submit that Section 17 of the AAT Act states:
S.17 – Transfer of ownership, etc., of antiquities to be initiated to the registering officer – Whenever ay person transfers the ownership, control or possession of any antiquity specified in any notification issued under sub-section (1) of Section 14 such person shall intimate, within such period and in such form as may be prescribed, the fact of such transfer to the registering officer.
34) I submit that Section 27 of the AAT Act states:
S.25 Penalty – (1) If any person, himself or by any other person on his behalf, exports or attempts to export any antiquity or art treasure in contravention of section 3, he shall, without prejudice to any confiscation or penalty to which he may be liable under the provisions of the Customs Act, 1962 as applied by section 4, be punishable with imprisonment for a term which shall not be less than six months but which may extend to three years and with fine.
(2) If any person contravenes the provisions of section 5 or section 12 or sub-section (2) or sub-section (3) of section 13 or section 14 or section 17, he shall be punishable with imprisonment for a term which may extend to six months or with fine or with both and the antiquity in respect of which the offence has been committed shall be liable to confiscation.
(3) If any person prevents any licensing officer from inspecting any record, photograph or register maintained under section 10 or prevents any officer authorised by the Central Government under sub-section (1) of section 23 from entering into or searching any place under the subsection, he shall be punishable with imprisonment for a term which may extend to six months, or with fine, or with both.
35) I submit that it is to be noted that the Assistant Commissioner/Executive Trustee of the Temple is an HR&CE Dept employee and thus a Government Servant. Section 12 of the HR&CE Act confirms this
S.12: Commissioner, etc., to be servants of Government. – (1) The
Commissioner, Additional Commissioner, Joint Commissioners, Deputy Commissioners, Assistant Commissioners and other officers and servants including executive officers of religious institutions employed for the purposes of this Act shall be servants of the Government and their salaries, allowances, pensions and other remuneration shall be paid in the first instance out of the Consolidated Fund of the State. The cost of auditing the accounts of religious institutions shall also be paid in the first instance out of the Consolidated Fund of the State.
36) I submit that it is learnt that the Temple officials have planned to stealthily remove the idol at an appropriate time after the closure of the Temple in the coming days.
37) I submit that the HR&CE Dept has no authority to replace any antique idol without appropriate government orders.
38) I submit that on 01.11.2025, I visited the Temple, verified the information is true, and on confirming, I had written a 22-page complaint to prevent the theft.
39) I submit that on 02.11.2025, Sunday, I visited the office of the Idol Wing CID, hereinafter referred to as the IWCID, only to find that the office is closed and there is no way I could lodge a complaint. The only guard outside the gates informed me that I had to come the next day to file the complaint.
40) I submit that on 03.11.2025, I visited the office of the IWCID respondent and submitted my written complaint with information of commission of cognizable offence. The same was received by the 3rd and 4th respondents from me in person.
41) I submit that S. 173 of the Bharatiya Nagarik Suraksha Sanhita 2023, hereinafter referred to as BNSS, details about the information in cognizable cases.
S. 173: (1) Every information relating to the commission of a cognizable offence, irrespective of the area where the offence is committed, may be given orally or by electronic communication to an officer in charge of a police station, and if given— (i) orally, it shall be reduced to writing by him or under his direction, and be read over to the informant; and every such information, whether given in writing or reduced to writing as aforesaid, shall be signed by the person giving it; (ii) by electronic communication, it shall be taken on record by him on being signed within three days by the person giving it, and the substance thereof shall be entered in a book to be kept by such officer in such form as the State Government may by rules prescribe in this behalf:
Provided that if the information is given by the woman against whom an offence under section 64, section 65, section 66, section 67, section 68, section 69, section 70, section 71, section 74, section 75, section 76, section 77, section 78, section 79 or section 124 of the Bharatiya Nyaya Sanhita, 2023 is alleged to have been committed or attempted, then such information shall be recorded, by a woman police officer or any woman officer:
Provided further that—
(a) in the event that the person against whom an offence under section 64, section 65, section 66, section 67, section 68, section 69, section 70, section 71, section 74, section 75, section 76, section 77, section 78, section 79 or section 124 of the Bharatiya Nyaya Sanhita, 2023 is alleged to have been committed or attempted, is temporarily or permanently mentally or physically disabled, then such information shall be recorded by a police officer, at the residence of the person seeking to report such offence or at a convenient place of such person’s choice, in the presence of an interpreter or a special educator, as the case may be;
(b) the recording of such information shall be videographed;
(c) the police officer shall get the statement of the person recorded by a Magistrate under clause (a) of sub-section (6) of section 183 as soon as possible.
(2) A copy of the information as recorded under sub-section (1) shall be given forthwith, free of cost, to the informant or the victim.
(3) Without prejudice to the provisions contained in section 175, on receipt of information relating to the commission of any cognizable offence, which is made punishable for three years or more but less than seven years, the officer in charge of the police station may with the prior permission from an officer not below the rank of Deputy Superintendent of Police, considering the nature and gravity of the offence,—
(i) proceed to conduct preliminary enquiry to ascertain whether there exists a prima facie case for proceeding in the matter within a period of fourteen days; or
(ii) proceed with investigation when there exists a prima facie case.
(4) Any person aggrieved by a refusal on the part of an officer in charge of a police station to record the information referred to in sub-section (1), may send the substance of such information, in writing and by post, to the Superintendent of Police concerned who, if satisfied that such information discloses the commission of a cognizable offence, shall either investigate the case himself or direct an investigation to be made by any police officer subordinate to him, in the manner provided by this Sanhita, and such officer shall have all the powers of an officer in charge of the police station in relation to that offence failing which such aggrieved person may make an application to the Magistrate.
42) I submit that the 5-judge constitutional bench of the Hon’ble Supreme Court of India in its judgment in Lalita Kumari v. State of Bihar, dated 12.11.2013, hereinafter referred to as the Lalita Kumari Case, had stated that the police shall register FIR if the complaint discloses information of commission of cognizable offence.
(i) Registration of FIR is mandatory under Section 154 of the Code, if the information discloses commission of a cognizable offence and no preliminary inquiry is permissible in such a situation.
(ii) If the information received does not disclose a cognizable offence but indicates the necessity for an inquiry, a preliminary inquiry may be conducted only to ascertain whether cognizable offence is disclosed or not.
(iii) If the inquiry discloses the commission of a cognizable offence, the FIR must be registered. In cases where preliminary inquiry ends in closing the complaint, a copy of the entry of such closure must be supplied to the first informant forthwith and not later than one week. It must disclose reasons in brief for closing the complaint and not proceeding further.
(iv) The police officer cannot avoid his duty of registering offence if cognizable offence is disclosed. Action must be taken against erring officers who do not register the FIR if information received by him discloses a cognizable offence.
(v) The scope of preliminary inquiry is not to verify the veracity or otherwise of the information received but only to ascertain whether the information reveals any cognizable offence.
(vi) As to what type and in which cases preliminary inquiry is to be conducted will depend on the facts and circumstances of each case. The category of cases in which preliminary inquiry may be made are as under:
• Matrimonial disputes/ family disputes
• Commercial offences
• Medical negligence cases
• Corruption cases
• Cases where there is abnormal delay/laches in initiating criminal prosecution, for example, over 3 months delay in reporting the matter without satisfactorily explaining the reasons for delay. The aforesaid are only illustrations and not exhaustive of all conditions which may warrant preliminary inquiry.
(vii) While ensuring and protecting the rights of the accused and the complainant, a preliminary inquiry should be made time bound and in any case it should not exceed 7 days. The fact of such delay and the causes of it must be reflected in the General Diary entry.
(viii) Since the General Diary/Station Diary/Daily Diary is the record of all information received in a police station, we direct that all information relating to cognizable offences, whether resulting in registration of FIR or leading to an inquiry, must be mandatorily and meticulously reflected in the said Diary and the decision to conduct a preliminary inquiry must also be reflected, as mentioned above.
43) I submit that despite this, the respondents have refused to register FIR and had also refused to give an acknowledgement of my complaint.
44) I submit that I sent the complaint vide registered post on 04.11.2025 to the 3rd respondent.
45) I submit that a copy of the same was also sent by email to the 2nd respondent by email on 07.11.2025. None of these complaints were acknowledged by the respondent till date.
SCOPE OF PRELIMINARY INVESTIGATION
46) I submit that Lalita Kumari case lists cases where preliminary investigation may be required by the investigative agency and the present case does not fall
in any of those categories. On the other hand, I have set the law in motion even before the theft is completed with an intent to prevent the crime, which otherwise will be irreparable.
47) I submit that the scope of preliminary investigation, as envisaged by the Hon’ble Supreme Court in the Lalita Kumari case as well as under S. 173(3) of the BNSS, is limited and well-defined, serving only to ascertain whether information discloses a prima facie cognizable offence and not to determine the veracity or conduct a full inquiry into the complaint.
48) I submit that as per Lalita Kumari case
(i) Preliminary inquiry is not required in every case; it is permitted only when the information does not, on its face, disclose a cognizable offence but may after basic verification (such as in cases of matrimonial, medical, or commercial nature). The present case does not fall in any of those buckets.
(ii) The purpose of the preliminary investigation is not to verify the truth of the allegations, but to check whether, if accepted on face value, the information discloses a cognizable offence warranting registration of FIR.
(iii) Once prima facie information is available, FIR shall be registered, and no further fact-finding or preliminary inquiry is permitted.
49) I submit that S. 173(3) of BNSS
(i) Recognizes preliminary inquiry for cognizable offences punishable with three years or more but less than seven years imprisonment
(ii) Such enquiry can be initiated by officer-in-charge, with prior approval of an officer not below Deputy Superintendent of Police (DS_), and must be completed in 14 days.
(iii) The scope is strictly to ascertain if there exists a prima facie case to proceed. If yes, FIR shall be registered immediately; if not, the complainant must be informed, enabling recourse to remedy.
50) I therefore submit that the common principles are
(i) The preliminary investigation is safeguard against abuse of law and to ensure only genuine cases of cognizable offences proceed.
(ii) It is not meant for detailed evidence-gathering, cross-examination, or to test the truth of the complaint.
(iii) If upon minimal checking, there appears a cognizable offence, the process moves promptly to FIR and formal investigation
Standard Lalita Kumari Section 173(3) BNSS
When
allowed Only in doubtful cases Offences 3+ to