Sumana Terunanse vs Kandappuhamy – clr volume 3 page 014_2

The case between Delgalle Sumana, Vitanamulla Dharmapale, Thammitta Dharmerakita and the parties in possession of Godagamuwa Vihare and its adjoining lands addressed the issue of succession to a Buddhist vihare when an incumbent dies without leaving a pupil. It was held that the termination of the line of pupillary succession precludes claims by co-pupils or others not expressly entitled under the traditional system. The court reaffirmed the principle that rights of incumbency follow the strict rules of pupillary lineage, and that departure from these rules—whether by attempted transfer, appointment, or shared succession—does not confer legal title. This decision relied on established precedents and the recognized customary law of vihare succession, clarifying that claims based on appointm