Indian law recognizes that a Hindu deity can possess legal personality. Since a deity is treated as a perpetual minor incapable of independently conducting litigation, the law permits a competent individual to represent the deity before courts as a "Next Friend."
This principle has been consistently recognized by Indian courts for more than a century.
The role of a Next Friend is fiduciary in nature. The representative does not claim ownership or personal benefit but acts solely to safeguard the interests of the deity.
The original suit on behalf of Shri Ram Lalla Virajman was instituted on 1 July 1989 in the Faizabad court by retired judge Justice Deoki Nandan Agarwala, who acted as the deity’s first Next Friend.
After Justice Agarwala’s death on 8 April 2002, Professor Thakur Prasad Verma of Banaras Hindu University took over the responsibility. In 2008, citing old age and ill health, Professor Verma stepped aside from the role, after which Shri Triloki Nath Pandey became the third Next Friend of Shri Ram Lalla Virajman.
His appointment ensured continuity in representing the deity after the Allahabad High Court’s 2010 judgment and during the appeals before the Supreme Court. Contemporary reports note that he took active responsibility for the case from around 2008 and continued in that capacity through the final 2019 verdict.
During the final hearings in 2019, Shri Triloki Nath Pandey remained the officially recognized representative of Shri Ram Lalla Virajman.
The legal arguments on behalf of the deity were principally presented by distinguished senior advocates, including:
While legal submissions were made by counsel, Pandey fulfilled the statutory role of representing the deity as the plaintiff in the proceedings.
On 9 November 2019, a Constitution Bench of five judges of the Supreme Court unanimously delivered its judgment in the Ayodhya title dispute. The judgment is widely regarded as one of the most consequential civil and constitutional decisions in independent India because it resolved competing claims over a site of deep religious and historical significance.
The Court held that:
The judgment concluded one of the longest civil title disputes in Indian legal history.
As the Next Friend(III) of Shri Ram Lalla Virajman, Shri Triloki Nath Pandey became closely associated with this historic legal milestone.