The Supreme Court has reserved its judgment on a plea filed by the Sambhal Mosque Management Committee challenging a trial court's order directing a survey of the Shahi Jama Masjid in Sambhal, Uttar Pradesh. The mosque committee argued that the survey order was passed ex parte, without giving them an opportunity to be heard, violating natural justice. The case raises critical questions about the Places of Worship (Special Provisions) Act, 1991 and due process rights under Article 21.

This case sits at the intersection of three constitutional and statutory layers that CLAT PG and UPSC CSE examiners frequently test.

**First, the Places of Worship (Special Provisions) Act, 1991.** This Act freezes the religious character of all places of worship as they existed on August 15, 1947, and bars courts from entertaining suits seeking to convert the character of any place of worship. The sole exception is the Ram Janmabhoomi-Babri Masjid dispute, which was explicitly carved out. The Sambhal case tests whether a court-ordered survey to 'ascertain' the original character of a mosque is itself a proceeding barred by this Act — because it effectively entertains the very inquiry the Act prohibits.

**Second, natural justice under Article 21.** The Supreme Court has consistently held, from Maneka Gandhi v. Union of India (1978) onwards, that any procedure affecting a person's rights must be fair, just, and reasonable. An ex parte survey order affecting a mosque's legal status without hearing the mosque committee arguably violates the audi alteram partem principle — a core component of procedural due process.

**Third, the Order VII Rule 11 CPC angle.** The mosque committee likely argued that the underlying suit itself was not maintainable under the 1991 Act and should have been rejected at the threshold before any survey was ordered.

The SC's reserved judgment will clarify how far trial courts can go in ordering religious-site surveys, and whether the 1991 Act creates an absolute bar or merely a procedural one.