Rev. Maiyawe Saddhananda Thero v. Ratnayake – sllr 1984 volume 2 page 373

In the case between the Controlling Viharadhipathi of Ratnagiri Rajamaha Vihara (representing the temple and the legacy of Rev. Maiyawe Saddhananda Thero) and a lay relation (Ratnayake) disputing title to certain land, the court addressed whether land granted under the Land Development Ordinance to a Buddhist monk devolves to the temple under section 23 of the Buddhist Temporalities Ordinance, or remains subject to the restrictive succession rules imposed by section 170 of the Land Development Ordinance. The court held that the statutory transformation effected by section 23 of the Buddhist Temporalities Ordinance prevails, thereby deeming the property as temple property upon the death of the incumbent, notwithstanding the statutory succession scheme otherwise applicable, thereby allowing