Somaratne Thero v. Pannaloka Thero and Others – sllr 1987 volume 1 page 225

In the case between Somaratne Thero (substituted plaintiff-appellant) and Pannaloka Thero and others (1st to 4th defendants), the court addressed the validity of an alleged oral nomination for the succession of the Viharadhipathy of Duwe Deeparamaya temple under Buddhist ecclesiastical law and the relevant Temporalities Ordinances. It was held that the evidence adduced was insufficient to establish a valid oral nomination as required by law, reaffirming the principle that nominations for temple succession must be precise, unequivocal, and corroborated in a manner akin to written declarations. The decision relied on the Ordinances of 1905 and 1931, as well as comparative analysis with past authorities, emphasizing that de facto incumbency does not displace the legal standard for succession.