Morawaka v. Dhammaratna Thero – 1978_79 volume 2 page 153

In the case between the Viharadhipathi of Wijayasiriwardhanaramaya (plaintiff-respondent) and Carolis Perera Morawaka (defendant-appellant), the court addressed the issue of whether a parcel of land constituted “Sangika Property” (dedicated temple property) under Buddhist law or remained personal property (“pudgalika”) despite long possession by a temple administrator. It was held that absence of evidence showing purchase with temple funds, formal dedication, or administration for temple benefit precluded its classification as Sangika Property. This holding reaffirmed the principle that establishing temple property requires clear and cogent proof of dedication or use of temple funds, and mere long possession is legally insufficient. The decision relied on analysis of documentary evidence,