Gammeddegoda Saranatissa Thero vs. Horangalle Samiddhi Thero – SC APPEAL NO. 92/2010-2018

In the case between Gammaddegoda Amarasiri Thero (substituted for Gammeddegoda Saranatissa Thero, deceased) and Horangalle Samiddhi Thero regarding the succession to the Viharadhipathiship (chief incumbency) of a Buddhist temple, the court addressed whether the interpretation of specific documents, particularly P2 (the Sangha Sabha resolution), P4, and P6, rightly established the entitlement to the temple’s Viharadhipathiship. It was held that these documents, when read in light of the Buddhist Temporalities Ordinance and the doctrine of pupillary succession, determined the rightful incumbent. The principle reaffirmed is that the designation of “Adhikari” in these circumstances is synonymous with “Viharadhipathi” in temple succession, with reliance placed on historical usage, established l